SAFE Credit Union California Consumer Privacy Act Policy

Last updated: November 2, 2020

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. These consumers do not include individuals applying for consumer financial products and services at SAFE or individual members of SAFE.

Your Rights under the California Consumer Privacy Act (CCPA)

The CCPA provides California residents (consumers) with rights regarding their personal information. This Policy describes how consumers can exercise their rights under the CCPA to request that we: (1) discontinue the sale of any personal information; (2) delete personal information that we have collected from them; and (3) provide certain personal information that we have collected about them during the preceding 12 months, along with related personal information described below.

Personal Information We Collect

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

  • Personal Identifiers such as name, address, email address, telephone number, or tax identification number
  • Protected Classifications such as gender, ethnicity, race, veteran status, or disability status
  • Biometric such as fingerprints, photographs, or voice recognition/recordings
  • References such as background checks, credit reports, personal/professional references, personality/aptitude tests reflecting character and abilities, or behavior attitudes
  • Geolocation such as physical location or movement
  • Internet or Internal Network Activity such as browsing or search history
  • Financial such as bank account number
  • Employment History such as previous employers or job performance indicators
  • Education History such as schools attended or degrees obtained
  • Personal Information of Emergency Contacts such as name, address, phone numbers, or relationship to the designated individuals
  • Personal Information of Dependents and Beneficiaries such as name, address, phone numbers, or relationship to employee
  • Commercial such as records of personal property or purchasing/consuming history

Sources from Which We Collect Personal Information:

  • Information you provide to SAFE to:
    • Apply for or open a business account, loan, or other business-related service
    • Enter sweepstakes or contests, or subscribe to a newsletter or blog
    • Complete job applications and other employment-related documents
  • Credit-reporting agencies
  • Third-party verification services
  • Internet search engines, including social media, and internal network activity
  • Security video
  • Public records
  • Government entities

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
  • Comply with equal employment opportunity laws
  • Comply with equal opportunity lending laws
  • Assess your qualifications for initial and ongoing employment
  • Contact designated individuals in the event of an emergency

Sharing and Disclosure of Personal Information

We do not share or disclose your personal information except as allowed by law for a business purpose. We share or disclose personal information with service providers who assist us in determining your eligibility for and servicing your products and services; or for employment services. We contractually require these service providers to not sell, share, or use your personal information for any other purposes. We share your personal information with attorneys and auditors for risk analysis and mitigation purposes only.

Right to Discontinue the Sale of Your Personal Information

We do not sell the personal information of consumers to any third party, including personal information about consumers under the age of 16 years.

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 within the preceding 12 months.

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

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 Non-Discrimination for the Exercise of Your Privacy Rights

You have a right to non-discriminatory treatment by us when you exercise any privacy rights under the CCPA.

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.

Notification of Changes

SAFE reserves the right to change or update this Policy in the future. When we do, we will post the revised Policy on our website. For questions about this Policy, contact us at (916) 979-7233 or (800) SEE-SAFE.

 
 
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