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CO-OP FINANCIAL SERVICES PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

CO-OP FINANCIAL SERVICES PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

1. INTRODUCTION

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of CU Cooperative Systems, Inc. and its affiliates (hereinafter, "CO-OP Financial Services" or “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws, demonstrate our firm commitment to your privacy and protection of your information.  Any terms defined in the CCPA have the same meaning when used in this Notice.

This policy covers how CO-OP Financial Services and its subsidiaries manage personal information that you submit, we collect and receive on our website, mobile applications, products and services or otherwise (hereinafter collectively, "Services"). We provide our Services to you subject to the following conditions (this “Notice”), which is subject to, and incorporated by reference into, our Terms and Conditions.

2. INFORMATION COLLECTION AND USAGE

Information We Collect

We may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Yes
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Yes
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Yes
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. Yes
G. Geolocation data. Physical location or movements. Yes
H. Sensory data. Current or past job history or performance evaluations, job title. Yes
I. Professional or employment-related information. Current or past job history or performance evaluations, job title. Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, student disciplinary records. Yes
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes

Personal information exempt from certain CCPA requirements include:

  • Publicly available information from government records.

  • De-identified or aggregated consumer information.

  • Information exempt from the CCPA requirements, including:

    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • 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.

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

  • Directly from our clients or their agents. For example, from documents that our clients provide to us related to the Services for which they engage us.

  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing Services to them.

  • Directly and indirectly from activity on our website (www.co-opfs.org) and mobile applications. For example, from submissions through our website portal or website usage details collected automatically.

  • From third-parties that interact with us in connection with the Services we perform. For example, from third-party service providers.

Use of Personal Information

CO-OP Financial Services may use or disclose the above-listed information, only as permitted by law, including for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is collected. For example, to complete transactions and provide Services authorized by you, or to complete transactions and provide the Services authorized by you.

  • To diagnose problems with the website or application, and to improve our website and its contents to you.

  • To send you information about your account, and to provide you with information, products or Services that you request from us.

  • To notify you of new products or applications being released, and other notices concerning our products or Services, or events or news, that may be of interest to you.

  • To prevent fraud and unauthorized transactions, to verify your identity, and to determine and confirm your transaction limits.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including to perform billing and collections.

  • To respond to law enforcement requests and as required to comply with applicable laws, court order, or governmental regulations.

  • To protect the personal safety of subscribers or the public, and to prevent and defend claims, to resolve disputes.

  • To troubleshoot problems, and for testing, research, analysis and development for our products and Services.

  • To enforce our Terms and Conditions for our Services, to protect our rights and property, and to customize, measure, and improve our Services.

  • As described to you when collecting your personal information and personal information may be used, internally, in a lawful manner that is compatible with the context in which the consumer provided the information, or as otherwise set forth in the CCPA.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

CO-OP Financial Services will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

3. INFORMATION SHARING AND DISCLOSURE

CO-OP Financial Services may share your information in the following limited circumstances:

  • When your consent is expressly provided.

  • With companies that assist us in administering and bringing you our services. The information shared with these companies typically includes information to process transactions on your behalf, conduct our operations, follow your instructions as you authorize, or protect the security of our financial records. These companies may include credit, product development, and data processing vendors.

  • With other financial institutions, such as member credit unions. The information shared with these financial institutions typically includes information to verify accounts, confirm transactions, and to coordinate and improve the services provided to you.

There are other situations when we may disclose to third parties your personal information, when permitted or required by law, such as in response to legal process or to government entities, or when you have requested us to share information about you with a third party.

This includes using tracking technologies, web server log files and tracking code, and information we receive through the use of these tracking technologies to analyze trends, administer this website, track users’ movement, and gather broad demographic information for aggregate use. Information of this type may be combined with other sources of information for these purposes. This allows us to recognize your needs and continue to make the improvements that are important to you and our customers.

We do not sell, rent, lease or disclose your personal information to third parties except if you consent to such disclosure or as described in this Notice. There are other situations when we may disclose to third parties your personal information, when permitted or required by law, such as in response to legal process or to government entities, or when you have requested us to share information about you with a third party. In the event that we go through a business transition, such as a merger, another company acquires us or our affiliates, or we sell a portion of our assets, your personal information will, in most instances, be part of the assets transferred. We may, but are under no obligation, to keep information we collect indefinitely.

We reserve and have the right to disclose any information about you or your use of this website without your prior permission if we have a good faith belief that such action is necessary to: (i) protect and defend our rights, property or safety or that or those of our affiliates, other users of this website, or the public; (ii) enforce the Terms and Conditions or other terms for this website; or (iii) respond to claims that any content violates any law or the rights of third-parties. We may also disclose information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request.

Personal Information Disclosed for a Business Purpose

CO-OP Financial Services may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, CO-OP Financial Services may have disclosed the following categories of personal information from Section 2 for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.

We may disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.

  • Service providers.

  • 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.

Personal Information Sold

In the preceding twelve (12) months, we have not sold any personal information, and we do not plan to sell any personal information.

4. HOW WE PROTECT YOUR PERSONAL INFORMATION

We have reasonable and appropriate security measures in place to attempt to protect against the loss, misuses, and alteration of your personal information under our control. We have taken reasonable steps to confirm the information is retained in secured facilities and that reasonable measures have been implemented for protection from unauthorized access.

No security system is impenetrable. We cannot guarantee the security of our website or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We ask that you do your part by maintaining any usernames and passwords you may use to access the Internet or this website strictly confidential.

5. CALIFORNIA RESIDENTS RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • 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 or selling that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

    • sales, identifying the personal information categories that each category of recipient purchased; and

    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer 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 such activities.

  3. Debug products to identify and repair errors that impair existing intended functionality.

  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  6. 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 the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  8. Comply with a legal obligation.

  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

6. Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at [888-771-5613]

Visiting www.co-opfs.org/CCPA

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.

Response Timing and Format

We 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.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  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 hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, 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.

  • Suggest that you may receive a different price or rate for goods or Services or a different level or quality of goods or services.

7. CHILDREN

The Services are not directed toward children under the age of sixteen and we do not knowingly collect any personal information from children under the age of sixteen. If a child provided this website with personal information, we ask that a parent or guardian send us a written request to the address listed below and we will promptly delete the child's information from our records.

8. PRIVACY NOTICE CHANGES

CO-OP Financial Services is always improving our Services. As our Services evolve, we may update or amend this Notice. If we modify this Notice, we will post the revised Notice online. The revised Notice will be effective immediately at the time of posting, unless a later effective date is expressly stated therein. We will also revise the "last updated date" stated above. It is your responsibility to periodically review this Notice. CO-OP Financial Services will review and update this Notice at least once every 12 months.  Users are bound by any changes to this Notice by using our Services after such changes have been first posted.

9. CONTACT INFORMATION

If you have any questions or concerns regarding CO-OP'S CCPA policies and practices, please call us at: 

888.771.5613 

Last updated on December 30, 2019.