SAFE Credit Union California Consumer Privacy Act Policy

Last updated: January 1, 2025

SAFE Credit Union (SAFE) created this California Consumer Privacy Act Policy (Policy) to demonstrate our firm commitment to consumer privacy.

This Policy discloses our personal information collection and sharing practices for consumers who are covered by the California Consumer Privacy Act and applies to:

Individual consumers associated with SAFE business accounts or loans,
Individuals who apply for employment with or are employed by SAFE, and
Individuals who provide information to SAFE other than in connection with obtaining SAFE business financial services or employment.

This policy does not apply to individuals who apply for or obtain SAFE financial services for personal, family, or household purposes.

Personal Information We Collect

The personal information that we collect will depend on your relationship with SAFE. Below are descriptions of the categories of personal information that we have collected about consumers in the preceding 12 months:

Identifiers such as a real name, alias, postal and physical address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license or state identification card number, passport number, or other similar identifiers.
- Sold, Shared or Disclosed: Shared and Disclosed
- Third parties we may share with or disclose to:
  - Service providers who assist SAFE in processing requests for and maintaining your products and services
  - Credit reporting agencies
  - Federal, State, or local government entities
  - Payroll and Benefits companies
  - Attorneys
  - Auditors
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.
- Sold, Shared or Disclosed: Shared and Disclosed
- Third parties we may share with or disclose to:
  - Service providers who assist SAFE in processing requests for and maintaining your products and services
  - Credit reporting agencies
  - Federal, State, or local government entities
  - Payroll and Benefits companies
  - Attorneys
  - Auditors
Characteristics of protected classifications under California or federal law. Includes, but not limited to: race, color, religion, sex, gender, sexual orientation, marital status, medical condition, military or veteran status, national origin, ancestry, disability, genetic information, age, citizenship, primary language, or immigration status.
- Sold, Shared or Disclosed: Shared and Disclosed
- Third parties we may share with or disclose to:
  - Service providers who assist SAFE in processing requests for and maintaining your products and services
  - Credit reporting agencies
  - Federal, State, or local government entities
  - Payroll and Benefits companies
  - Attorneys
  - Auditors
Biometric information. Includes, but not limited to, an individual’s physiological, biological, or behavioral characteristics.
- Sold, Shared or Disclosed: Shared and Disclosed
- Third parties we may share with or disclose to:
  - Service providers who assist SAFE in processing requests for and maintaining your products and services
  - Credit reporting agencies
  - Federal, State, or local government entities
  - Payroll and Benefits companies
  - Attorneys
  - Auditors
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
- Sold, Shared or Disclosed: Shared and Disclosed
- Third parties we may share with or disclose to:
  - Service providers who assist SAFE in processing requests for and maintaining your products and services
  - Credit reporting agencies
  - Federal, State, or local government entities
  - Payroll and Benefits companies
  - Attorneys
  - Auditors
Geolocation data.
- Sold, Shared or Disclosed: Shared and Disclosed
- Third parties we may share with or disclose to:
  - Service providers who assist SAFE in processing requests for and maintaining your products and services
  - Credit reporting agencies
  - Federal, State, or local government entities
  - Payroll and Benefits companies
  - Attorneys
  - Auditors
Audio, electronic, visual, or similar information.
- Sold, Shared or Disclosed: Shared and Disclosed
- Third parties we may share with or disclose to:
  - Service providers who assist SAFE in processing requests for and maintaining your products and services
  - Credit reporting agencies
  - Federal, State, or local government entities
  - Payroll and Benefits companies
  - Attorneys
  - Auditors
Professional or employment-related information.
- Sold, Shared or Disclosed: Shared and Disclosed
- Third parties we may share with or disclose to:
  - Service providers who assist SAFE in processing requests for and maintaining your products and services
  - Credit reporting agencies
  - Federal, State, or local government entities
  - Payroll and Benefits companies
  - Attorneys
  - Auditors
Inferences drawn from information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Sold, Shared or Disclosed: No
- Third parties we may share with or disclose to: None

Use of Sensitive Personal Information :

We do not use sensitive personal information other than to perform the services requested, detect security incidents, prevent fraudulent actions, or perform services on behalf of the business such as providing member service, processing transactions, and providing financial services.

Sensitive personal information means:

A consumer’s Social Security, driver’s license, state identification card, or passport number.
A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
A consumer's precise geolocation.
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.
A consumer's genetic data.
A consumer’s neural data that is generated by measuring the activity of a consumer’s brain or nervous system, and excludes things like body language, facial expressions, or other external clues that might suggest what the person is thinking or feeling.

Purpose of Collecting Personal Information:

Verify your identity
Contact you regarding application status and process
Maintain security
Administer payroll and employee benefits
Assign computers and software programs
Provide you information on financial products and services
Maintain your accounts and services
Assess your qualifications for a business account or loan
Assess your financial standing with SAFE
Process your sweepstakes or contest entry
Manage your blog or newsletter subscriptions
Process release authorizations
Process notification alerts
Monitor and evaluate compliance with equal employment opportunity laws
Monitor compliance with non-discrimination laws, and the collection and reporting of information consistent with fair lending laws
Assess your qualifications for initial and ongoing employment
Contact designated individuals in the event of an emergency
Assess your eligibility for a scholarship

Right to Have Your Information Deleted

You may request deletion of your personal information by contacting us in one of the ways described below. We may deny your deletion request if retaining the personal information is necessary for us or for our service providers to:

Complete the transaction for which the information was collected.
Provide a product or service you have requested or reasonably anticipated within the context of our ongoing relationship with you.
Perform a contract between us and you.
Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
Debug or identify and repair errors.
Comply with a legal obligation.
Otherwise use your information internally, in a lawful manner that is compatible with the context in which you provided the information.

Right to Know About Personal Information Collected, Used, or Disclosed

As a consumer, you have the right to request that we disclose certain information to you about our collection and use of your personal information.

We will acknowledge your request within 10 business days and will provide the requested information or reply within 45 calendar days of receipt of the request. If we are not able to respond within 45 calendar days, we will notify you and respond within an additional 45 calendar days (for a maximum total of 90 calendar days from the day the request was received). We reserve the right to verify the legitimacy of all requests, using any information you have given us, or any transactional information we have. We are prohibited from providing the following:

Your Social Security number
Driver’s license or other government-issued identification number
Account number
Account passwords or security questions and answers
Any health insurance or medical identification number
Any biometric information

Right to Opt-out of Sharing Personal Information or Sensitive Personal Information

You have the right to direct SAFE to not share your personal information with third parties by contacting us in one of the ways below. We may deny your request because SAFE only shares personal information of consumers with other businesses or third parties to process requests as directed by the consumer.

If you wish to submit a request for personal information we collect, use, or disclose, contact us using one of the following methods:

Call us at (916) 979-7233 or (800) SEE-SAFE.
Submit your request online.
Mail your request to:
SAFE Credit Union
Attn: Privacy
2295 Iron Point Road, Suite 100
Folsom CA 95630
Visit any of our SAFE branch locations.

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

If you submit your request in person, we may ask to see a current government-issued photo ID such as a driver’s license, passport, or military ID. If you make your request by phone, mail, or via our online portal, we may ask for information that allows us to verify your identity by comparing the information you provide against the information in our records.

Right to Use an Authorized Agent

You may designate an authorized agent to make a request under the CCPA on your behalf. We retain the right to verify the legitimacy of that designation, and to identify both you and the agent. We will identify you with the information you have previously provided to us and with information about your account(s) or transactions.

We cannot respond to an authorized agent’s request or provide personal information if we cannot verify your identity, the identity of the authorized agent or authority to make the request, and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.