Privacy

Last Updated: 10/1/2024

California Credit Union understands the importance of protecting your privacy. Our goal is to maintain your trust and confidence when handling your personal information.  We are committed to maintaining the confidentiality of your personal information consistent with state and federal laws. This Online Privacy Policy (“Policy”) describes how we collect, use, share and protect information when you visit or use our website, www.ccu.com and mobile application, CCU Mobile Banking. The term “us,” “we” or “our” in this Policy refers to California Credit Union.  References to “you,” “your,” and “yours” shall mean the members, customers and website visitors and users of our app. The term “app” includes our mobile application that runs on smartphones, tablets, and other devices, through which you will be able to access online banking services such as getting real-time balances for your accounts, manage your money, viewing your transactions and statements, transfer funds, pay your bills, deposit a check, receive alerts and manage your debit/credit cards with us. Unless otherwise stated herein, references to our online services shall refer to any services available to you through our website and/or app, including but not limited to, online banking services.

By using the online services, our website or our app, you agree to the terms and conditions of this Policy and consent to our online data collection activities as described in this Policy.

The terms “personal information” or “personally identifiable information” used in this Policy refers to information such as your name, mailing address, email address, telephone number, Social Security number or other information that identifies you. This information may be collected when you voluntarily provide it to us on our website or in our app, when you create an account, when you use our online banking services and when you provide feedback or contact us via e-mail. The term “online activity data” refers to such information as IP address; browser type; display/screen settings; how you interact with our e-mails, websites and app, including your use of our online services; mobile device and advertising IDs; social media preferences and other social media data; location data (if you have enabled location services on your device); and other data that may be aggregated and may identify individual consumers/customers.

INFORMATION WE COLLECT ONLINE – AND HOW WE COLLECT IT

You may visit our websites to find out about products and services and check rates, without giving us any personal information. We, and our service providers, may use software tools and/or “cookies” to track and gather information about your browsing activities in order to analyze usage, target areas for improvement and create marketing programs to benefit our members or potential members that visit our site. Tracking may include the date and time of visits, pages viewed, time spent on our site, browser types, device data, the use of local storage technologies, location information, IP address and the site visited just before and just after our site. As part of our security procedures for members using our online banking services to conduct account inquiries and transactions, we require personally identifiable information such as a login identification (username) and password. We may also collect certain information from identity verification services and consumer reporting agencies, including credit bureaus, to provide certain online banking services. We may use a cookie to authenticate your request.

I) Use of Cookies and Similar Tracking Technologies

The use of cookies and similar tracking technologies (including pixels or clear GIFs, tags and web beacons) is a common internet practice. Cookies are small text files containing small amounts of information which are downloaded to your computer, smartphone, tablet or other mobile device when you visit a website. Cookies are useful in a number of ways, including allowing a site or mobile app you use to recognize your device, save your settings on a site or mobile app, facilitate navigation, display information more effectively and to personalize the user’s experience. Cookies are also used to gather statistical information about how sites and mobile apps are used in order to continually improve design and functionality and assist with resolving questions regarding the sites and mobile app.

a. Attributes of Cookies

Cookies set by us are called first-party cookies. We may also have third-party cookies, which are cookies from a domain different than the domain of the website you are visiting, for our advertising and marketing efforts. There can be first-party and/or third-party cookies within any of the below Categories of Cookies.

Cookies have a duration period. Cookies that expire at the end of a browser session are called “session” cookies. Cookies that are stored longer are called “persistent” cookies. There can be session and/or persistent cookies within any of the below Categories of Cookies. Persistent cookies are stored on your system and can be accessed again for multiple visits. Persistent cookies usually have an expiration date and will be automatically deleted from your system at that time.

b. Categories of Cookies

Below is a list of the types of cookies that may be used on our websites. We classify cookies into the following categories:

Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Functional Cookies: These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Targeting Cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

c. How to Control and Delete Cookies

Using Your Browser

Many of the cookies used on our websites can be enabled or disabled through our consent tool or by disabling the cookies through your browser. To disable cookies through your browser, follow the instructions usually located within the “Help,” “Tools” or “Edit” menus in your browser. Please note that disabling a cookie or category of cookies does not delete the cookie from your browser unless manually completed through your browser function.

A growing number of browsers have adopted Global Privacy Control (“GPC”). The GPC is a technical specification designed to allow internet users to notify businesses of their privacy preferences, such as whether they want their personal information to be sold or shared for behavioral advertising purposes. Where required to do so under applicable law, our websites will honor GPC opt-out signals.

Using Your Mobile Device

Some mobile devices come with a non-permanent advertising identifier or ID which gives companies the ability to serve targeted ads to a specific mobile device. In many cases, you can turn off mobile device ad tracking or you can reset the advertising identifier at any time within your mobile device privacy settings. You may also choose to turn off location tracking on your mobile device. By turning off ad tracking or location tracking on your mobile device, you may still see the same number of ads as before, but they may be less relevant because they will not be based on your interests.

Online Advertising & Cross Context Behavioral Advertising

You may see advertisements when you use many of our online services. These advertisements may be for our own products or services (including pre-screened offers of credit) or for products and services offered by third parties. Which advertisements you see is often determined using the information we or our affiliates, service providers and other companies that we work with have about you, including information about your relationships with us (e.g., types of accounts held, transactional information, location of banking activity). To that end, where permitted by applicable law, we may share with others the information we collect from and about you.

Cross-context behavioral advertising refers to the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s activity across businesses, distinctly branded websites, applications or services, other than the business, distinctly branded website, application or service with which the consumer intentionally interacts. Through this type of advertising, we hope to deliver advertisements that are most likely to be of interest to you using information about your other web-browsing activities (e.g., the web pages you visit, search terms you enter and the way you move through our online services on your computer or device) or your personal profile (e.g., demographic or location information). Certain companies we work with may set cookies and use related tracking technologies, such as the clear GIFs discussed above, throughout our online services or in our communications to support these advertising efforts.

If you do not want us to share your information with companies we work with for cross-context behavioral advertising purposes, you can opt-out by:

• Clicking on the following links: Google Ad Center, Facebook Ad Preferences.
• If you are a California resident, you may also opt-out through the “Do Not Sell or Share My Personal Information” link on the homepage of our website.

Please note that even if you opt out, you may still receive advertisements from us; they just won’t be customized based on your web-browsing activities on third-party websites.

Cookie Settings

You may manage the cookies that run on our website’s Privacy Preference Center by clicking “Cookie Settings” on our website’s homepage.  Except for strictly necessary cookies, you have the option of turning off targeting, performance and functional cookies.

Third-Party Website Cookies That We Cannot Control

When using our websites, you may be directed to other websites for activities such as surveys, completing job applications and to view content hosted on those sites such as an embedded video or news article. These websites may use their own cookies. We do not have control over the placement of cookies by other websites you visit, even if you are directed to them from our websites.

Location Data

When allowed by you, our app collects your location data to provide you with location-based services, such as identifying branches and ATMs near you, and location-based messages and offers. Location access can be allowed once, only while using the app or you can choose to not allow location data to be collected.

IP Address

If you log on to our websites to access our online services, including but not limited to the online banking page, you may pass through a “firewall” used for security purposes and the Internet Protocol (IP) address associated with the device you are using may be identified. In certain instances, it may also obtain other information about your device to better identify you as an online user. This information may be retained in case it is needed for security or protection of member information.

Social Media

We may collect information, such as your likes, interests, feedback and preferences when you interact with our official pages on social media websites such as Facebook, X, LinkedIn, YouTube and Instagram or from our social media partners (but only if you choose to share with them and they, in turn, share that information with us). Please refer to the policies of those companies to better understand your rights and obligations with regard to your activity on those websites.

Contact Information and Images

With your permission, our app may be granted access to your phonebook or contact information in your mobile device to provide various features like Zelle Payments. We will only disclose this information as necessary to enable such features and to comply with federal, state or local laws or other legal requirements.

Our app may request access to your camera for you to be able to use our remote deposit capture service.  The front and back pictures of the checks you send will only be used for our remote deposit capture service.  Such images will only be accessible by us and our service providers that help enable our remote deposit capture service.  We will only disclose the check photos to third parties if necessary to process your remote deposit and to comply with federal, state or local laws, or other legal requirements.

Additionally, if you are applying for membership on our website, we may ask you to upload a copy of your government issued identification card for us to comply with our regulatory requirements. We will only use this information to open your account and disclose this information to third parties as necessary to process your membership application and to comply with federal, state or local laws, or other legal requirements.

Chat Feature

We have partnered with Digital Insight Corporation (“Digital”) to offer a Chat feature on our website and mobile application.  All content and data provided during your Chat session, including interactions, communications, images, videos and audio, may be monitored, recorded, transcribed and/or received by us, Digital and their respective service providers for training, quality control, analytics and other lawful purposes.  Your use of the Chat feature constitutes your consent to such monitoring, recording and transcription.  We will use your information in ways that are described in this Policy.

Digital’s collection, storage, use and subsequent disclosure of your nonpublic personal information to third parties, including its service providers, is limited under our agreement with Digital so such information may be processed only in connection with providing us with contracted services, required disclosures such as subpoenas, and for other lawful purposes.

Text Messaging

We have partnered with certain service providers to offer banking services via text messaging.  Any personal information transmitted via the text messaging service will be collected by us and will not be shared outside of our contractual relationship with our service providers for their limited use in fulfilling their contractual obligations in delivering such services.  We will not share your personal information collected via the text messaging service with any other party.

HOW WE USE INFORMATION WE COLLECT

We do not and will not sell your personal information. We share your information as required to meet legal and regulatory obligations. We share your personal information that you have provide to us in connection with applying for membership and/or financial products with us (“personally identifiable financial information”) with affiliates and third parties in accordance with the practices set forth in our Federal Privacy Policy.

With respect to other information that we collect from you online, which includes personal information from the use of our online services as well as online activity data, we use such information for a variety of reasons, including:

• to present our websites and their contents to you;
• to enable you to use online tools or perform certain online transactions;
• to service and manage your account, including responding to or updating you on inquiries, or to contact you about your accounts or feedback;
• to offer you special products and services and deliver advertisements to you in the form of banner ads, interstitial pages (ads that appear as you sign in or sign out of your online accounts) or other promotions;
• to analyze whether our ads, promotions and offers are effective;
• to help us determine whether you might be interested in new products or services and to improve existing products and services;
• to verify your identity and/or location to allow access to your accounts and conduct online transactions;
• to manage fraud and data security risk;
• to personalize and optimize your website browsing and app experiences by examining which parts of our website you visit or which aspect of our apps you find most useful;
• to protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• to audit our internal processes for compliance with legal and contractual requirements, as well as our internal policies;
• to comply with federal, state or local laws; civil, criminal or regulatory investigations; or other legal requirements; and
• to share with trusted third parties who are contractually obligated to keep such information confidential and to use it only to provide the services we have asked them to perform.

By using the online services, our website or our app, we may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties in our discretion.

WHO WE SHARE INFORMATION WE COLLECT WITH

We disclose your personal information and online activity data to third parties for only our business purposes and to comply with our legal requirements. The general categories of third parties that we share with are as follows:

• our third-party service providers;
• other companies to bring you co-branded services, products or programs;
• third parties that help us advertise our products or services;
• third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you;
• third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of our company or affiliated business; and
• other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise, to protect the rights, property or security of our customers or third parties.

MISCELLANEOUS

Updating Your Personal Information: Keeping your account information up-to-date is important. You can access and/or update your personal information in connection with your account or application by logging on to your account online or contacting us.

Security: Protecting the confidentiality and security of your personal and financial information is our highest priority. We value your trust, and we understand that handling your financial information with care is one of our most important responsibilities. Our policies, procedures and protections are always evolving to adapt to new strategies used by fraudsters. Our security measures include ensuring that our websites, online services, online banking, mobile banking and online applications are hosted on secure servers, have SSL certificates, device safeguards and secured files and buildings, as well as oversight of our third-party service providers that have access to your personal information and limiting our employees’ access to your personal information on a need to know basis.

What You Can Do to Help Protect Your Information: We are committed to protecting your privacy. We suggest you follow these guidelines:

• Protect your account numbers, card numbers, personal identification numbers (PINs) and passwords. Never keep your PIN with your debit or credit card which would provide access to your accounts if your card is lost or stolen.
• Use caution when disclosing your account numbers, Social Security numbers and other confidential information to other If someone calls you, explains the call is on behalf of us and asks for your account number, you should beware. Our staff will have access to your information and will not need to ask for it.
• It is important that we have your current information so we may reach you. If we detect potentially fraudulent or unauthorized activity or use of any account, we will attempt to contact you immediately. If your address, phone number or email changes, please let us know

Linking to Other Websites: Our websites, online services, online or mobile banking may contain links to third party websites. Although these links were established to provide you with access to useful information, we do not control and are not responsible for any of these websites or their contents. We do not know or control what information third-party websites may collect regarding your personal information. We provide these links to you only as a convenience, and we do not endorse or make any representations about using such third-party websites or any information, software or other products or materials found there, or any results that may be obtained from using them. We encourage you to review the privacy statements of websites you choose to link to from our websites so that you can understand how those websites collect, use and share your information. We are not responsible for the security or privacy practices of the linked websites.

Protecting Children’s Privacy: We respect the privacy of children and comply with the practices established under the Children’s Online Privacy Protection Act (COPPA). We do not knowingly collect or retain personally identifiable information from consumers under the age of thirteen. We may, however, collect information about consumers under the age of thirteen directly from their parents or legal guardians or with their prior knowledge and consent in connection with the financial products and service that we offer to our members, such as, without limitation, adding children as beneficiaries to bank accounts. For more information about COPPA please visit the Federal Trade Commission website: www.ftc.gov.

Data Retention: We may retain your personal information and online activity data even if you decide to terminate your membership with us, close your accounts with us and/or delete our app or cease use of our websites based on the following:

• Laws and regulations. We are a regulated financial institution that is subject to laws and regulations governing our retention of information pertaining to our members, applicants for credit union membership, loans and other financial products and services. We are also an employer and, thus, we are subject to labor laws governing how long we must retain information about applicants for employment and current and former employees. Therefore, applicable laws and regulations will govern how long we retain information pertaining to you.
• Fraud Prevention and Security. We will retain information that we need for fraud prevention and security purposes.
• Contracts. We will retain information for as long as necessary to comply with our contractual obligations to you, our service providers and other third parties, as permitted by law.
• Legal Claims and Defenses. We may retain information for such a period as necessary or advisable to preserve legal claims and defenses.

Opting Out of Email or SMS Communications. If you have signed-up to receive our email marketing communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information under “Contact Us” below. If you provide your phone number through the online banking services, we may send you notifications by SMS, such as providing a fraud alert. You may opt out of SMS communications by unlinking your mobile phone number through the online banking services.

Contact Us: You may contact us regarding any question, concern or matter pertaining to this Policy at:

Phone: (800) 334-8788

Website: www.ccu.com

Email: [email protected]

Mail:    Attn: Compliance & Vendor Management

5898 Copley Drive

San Diego, California 92111

Updates to this Policy: From time to time, we may change this Policy. The effective date of this Policy, as indicated above, reflects the last time this Policy was revised. Any changes to this Policy will become effective when we post the revised Policy on our website. Your use of our websites, online services or online or mobile banking following these changes means that you accept the revised Policy.

What does California Credit Union do with your personal information? 

FACTS

• Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.
• What? The types of personal information we collect and share depend on the product or service you have with us. This information can include:
  – Social Security Number and Income
  – Account Balances and Payment History
  – Credit Score and Credit History
• How? All financial companies need to share members’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their members’ personal information, the reasons California Credit Union chooses to share and whether you can limit this sharing.

To Limit Your Sharing
Call (800) 334-8788

Please note: If you are a new member, we can begin sharing your information thirty (30) days from the date we sent this notice. When you are no longer our member, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

What we do

Definitions

Other Important Information

For California Residents: We will provide a separate short form notice describing the rights of California residents to opt-out of the sharing of your non-public personal information in accordance with the California Financial Information Privacy Act. We have also provided a separate Consumer Privacy Notice notifying you of your rights under the California Online Privacy Protection Act and the California Consumer Privacy Act of 2018 on our website.

For Nevada Residents: We are providing this notice pursuant to Nevada law. If you prefer not to receive marketing calls from us, you may be placed on our Internal Do Not Call List by calling (800) 334-8788. For more information, contact us at this toll-free number. You may also contact the Nevada Attorney General’s office: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; telephone number: (702)-486-3132; email [email protected].

Click here for mail in form

Last Updated: 10/1/2024

This California Consumer Privacy Act Privacy Policy (“CCPA Privacy Policy”) explains how we collect, share, use and protect your personal information through your online and offline interactions with us. This CCPA Disclosure applies to residents of California to the extent that the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), applies to California Credit Union.  As used in this CCPA Privacy Policy, “personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  However, personal Information does not include: (i) publicly available information; (ii) deidentified or aggregated consumer information; or (iii) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”) and the Gramm-Leach-Bliley Act (“GLBA”).

The specific personal information that we collect, use and disclose relating to a California resident in different contexts covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this CCPA Disclosure does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family or household purposes (i.e., information subject to the GLBA). For more information about how we collect, disclose and secure information relating to these customers, please refer to our Federal Privacy Policy. We may use the information described below for any of the purposes described in this CCPA Privacy Policy or for our business, security or operational purposes compatible with the context in which the personal information was collected, unless limitations are listed in this CCPA Privacy Policy or described elsewhere at the time of collection of the information.

I. CATAGORIES OF INFORMATION WE COLLECT

In the preceding 12-months, we have collected the following categories of personal information (please note that some categories overlap):

For purposes of the CCPA, “personal information” does not include:

• Publicly available information.
• De-identified information that cannot reasonably be used to identify you or your household.
• Aggregated consumer information that relates to a group or category of consumers, from which consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device.
• Information excluded from the CCPA’s scope like personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

II. CATEGORIES FOR SOURCES OF INFORMATION WE COLLECT

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from consumers or their agents. For example, from forms you complete, when you perform transactions and when you purchase products or services.
• Indirectly from consumers or their agents. For example, when you use your debit or credit cards, when you make deposits or withdrawals to/from your accounts or when you pay your bills.
• Directly and indirectly from activity on our website or our mobile applications. For example, from submissions through our website, application portals or website usage collected automatically.
• From third-parties, such as credit reporting agencies, government agencies, law enforcement agencies and service providers.

III. HOW WE USE YOUR PERSONAL INFORMATION

We may use or disclose personal information we collect for one or more of the following operational or other notified purposes (“business purposes”):

• To fulfill or meet the reason for which the information is provided. For example, if you apply for a loan, we use the information in your loan application to evaluate your credit request and grant you the loan if approved.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations or other notices concerning our products or services or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research and analysis to improve our products and services and for developing new ones.
• To protect the rights, property or safety of us, our employees, our members or others.
• To detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity.
• To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
• As described to you when collecting your personal information.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, in which personal information held by us is among the assets transferred.
• As otherwise permitted under law.

With respect to your personal information that is deemed “sensitive personal information” under the CCPA, we do not use or disclose it for any purpose other than, as reasonably necessary and proportionate, for the following purposes:

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods and services.
• To prevent, detect and investigate security incidents that compromise the availability, authenticity, integrity or confidentiality of stored or transmitted personal information.
• To resist malicious, deceptive, fraudulent or illegal actions directed at the business and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside of your current interaction with us.
• For our service providers or contractors to perform services on our behalf, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage or providing similar services on our behalf; provided, however, that the use of your sensitive personal information is reasonably necessary and proportionate for this purpose.
• To verify or maintain the quality or safety of a service or device that is owned, manufactured for or controlled by us, and to improve, upgrade or enhance the service or device that is owned, manufactured for or controlled by us; provided, however, that the use of your sensitive personal information is reasonably necessary and proportionate for this purpose.
• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about you.

IV. HOW WE SHARE AND DISCLOSE PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this CCPA Privacy Policy, we may disclose your personal information in the following situations:

• Service Providers. We may share your information with service providers.  Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, process payments, assist in the fulfillment of services and help us market our own products and services.
• Joint Marketing Partners. We may share your information with other companies to offer you co-branded financial products and services.
• Advertising Networks. We may share your information with advertising networks such as Google and Facebook to help deliver our advertisements to you as you are browsing online.
• Compliance with Laws and Other Lawful Uses. We may disclose information to law enforcement agencies and other government entities or private parties in litigation in response to subpoenas, warrants or court orders, or in connection with any legal process, or to comply with relevant laws.  We may also share your information with this parties to establish or exercise our rights, to defend against a claim, to investigate, prevent or take action regarding possible illegal activities, suspected fraud, safety of person or property or a violation of our policies.  We may also disclose your personal information with our acquisition or merger partners in the event of an acquisition or merger.  Furthermore, we may disclose your personal information as permitted by applicable law.  All of the categories of personal information we collect from you may disclosed for this purpose.
• Your Consent. All the categories of personal information we collect from you may be disclosed to third parties with your consent or direction.

In addition to the information above, California law requires that organizations disclose whether the specific categories of personal information defined in the CCPA have been disclosed to third parties for a “business purpose,” or “sold” or transferred for “valuable consideration,” or “shared” for purposes of cross-context behavioral advertising.  The table below indicates which of these specified categories we may collect and transfer in a variety of contexts.

V. YOUR RIGHTS AND CHOICES

This section describes your rights and choices regarding how we collect, share, use and protect your personal information, how to exercise those rights and limits and exceptions to your rights and choices.

a. Exceptions

The rights and choices in this Section do not apply:

• If you are not a California resident;
• If we collected personal information covered by certain financial sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) and/or California Financial Information Privacy Act (“CFIPA”). How we collect, share, use and protect your personal information is covered under such laws instead of the CCPA; or
• To aggregate consumer information; or
• To deidentified personal information; or
• Publicly available personal information.

b. Right to Know

If the above exceptions do not apply, and you have not made this request more than twice in a 12- month period, you have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your request and verify that the request is coming from you or someone authorized to make the request on your behalf, we will disclose to you or your representative:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting, sharing or selling that personal information, as applicable.
• The categories of third parties to whom we disclosed, shared or sold the personal information, as applicable.
• The specific pieces of personal information we collected about you in a form that you can take with you (also called a “data portability request”).

c. Right to Delete

You have the right to request that we delete any of your personal information that we collect from you and retained, subject to  certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
2. Detect security incidents; protect against malicious, deceptive, fraudulent or illegal activity; or prosecute those responsible for that activity;
3. Debug to identify and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech or exercise another right provided for by law;
5. Engage in public or peer-reviewed scientific, historical or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you previously provided informed consent;
6. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; or
7. Comply with a legal obligation.

d. Right to Correction

You have the right to request correction of any personal information that we retain about you that is incorrect. We generally rely on you to update and correct your personal information.

e. Exercising Access, Data Portability, Deletion and Correction Rights

To exercise the access, data portability, deletion and correction rights described above, you or your authorized agent may submit a verifiable consumer request to us by any of the following methods:

• Calling us at (800) 334-8788
• Completing the CCPA Request Form.
• Emailing us at [email protected].
• Visiting one of our branch locations

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

When we receive a verifiable request from your authorized agent we may require:

1. Submission of a written document signed by you with your permission for the authorized agent to submit a verifiable request on your behalf and require the authorized agent to verify its own identity to us; or
2. You may directly verify with us that you have authorized the agent to submit the request.

We will not require either of the above if the authorized agent provides a copy of a power of attorney pursuant to California Probate Code sections 4121 to 4130 and we are able to verify the authorized agent’s identity.

We will deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf and cannot verify their own identity to us.

We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response to the mailing address of record according to our files.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hinderance.

The response we provide will also explain the reasons we cannot comply with a request, if applicable.  We do not charge a fee to process or respond to your verifiable consumer request.

f. Right of Non-Discrimination

We will not discriminate against you for exercising any of your rights in this Disclosure and under applicable laws. Unless permitted by law, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price for goods or services or a different level or quality of goods or services

g. Opt-Out Rights Regarding Sale of Personal Information or Sharing Personal Information for Cross-Context Behavioral Advertising

It is not our policy to sell personal information and we have not done so in the preceding 12-month period.

In the preceding 12-months, we have shared your personal information to deliver cross-context behavioral advertisements to you.

To exercise this right, please click on the “Do Not Sell or Share My Personal Information”  link on the homepage of our website or mobile application.

If we receive an opt-out preference signal in a format commonly used and recognized by businesses, we will accept the signal as a valid request to opt-out of sale/sharing for the particular browser or device from which the signal was sent, and if we are able to identify you from your browser or device, we will accept the signal as an opt-out of sale/sharing for your personal information as well. In most instances, we will not be able to identify you from your browsers or device, so if you would like to opt-out of the sale/sharing of your personal information that may occur offline, please opt-out through the “Do Not Sell or Share My Personal Information”  link, through which we will ask for additional information to identify you.

VI. CHANGES TO THIS DISCLOSURE

We reserve the right to amend this CCPA Privacy Policy at our discretion and at any time. When we make changes to this Disclosure, we will post an updated CCPA Privacy Policy on our website and mobile application.

VII. CONTACT INFORMATION

If you have any questions or comments about this CCPA Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights, or to request changes to any of your personally identifiable information that we have collected, please do not hesitate to contact us at:

Phone: (800) 334-8788

Website: www.ccu.com

Email: [email protected]

Mail:    Attn: Compliance & Vendor Management

5898 Copley Drive

San Diego, California 92111