ONLINE PRIVACY POLICY
Last Updated: March 26, 2024
Spectrum 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. https://www.spectrumcu.org and mobile application, Spectrum Credit
Union Mobile. The term “us,” “we” or “our” in this Policy refers to Spectrum 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. 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. 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 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, IP address, and the site visited just before and just after our
site. As part of our security procedures for members using our online services
to conduct account inquiries and transactions, we require personally
identifiable information such as a login identification (username) and
password. We may use a cookie to authenticate your request.
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:
Essential Cookies: These cookies are
technically necessary to provide website functionality. They are a website’s basic form of memory,
used to store the preferences selected by a user on a given site. As the name
implies, they are essential to a website’s functionality and cannot be disabled
by users. For example, an essential cookie may be used to prevent users from
having to log in each time they visit a new page in the same session.
Performance and Function Cookies: These cookies are
used to enhance the performance and functionality of a website,
but are not essential to its use. However, without these cookies,
certain functions (like videos) may become unavailable.
Analytics and Customization Cookies: Analytics and
customization cookies track user activity, so that website owners can better
understand how their site is being accessed and used.
Advertising Cookies: Advertising
cookies are used to customize a user’s ad experience on a website. Using the
data collected from these cookies, websites can prevent the same ad from
appearing again and again, remember user ad preferences, and tailor which ads
appear based on a user’s online activities.
c.
How to Control and Delete Cookies
1.
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.
2.
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.
3.
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. Our advertising service
providers may deliver our advertisements to you on non-affiliated
websites. Such service providers control
the manner in which the advertisements are delivered
to you on such non-affiliated websites.
You should generally be able to opt-out of receiving such advertisements
from the service provider responsible for delivering the advertisement.
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.
We do not engage in cross-context behavioral advertising.
4.
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.
2)
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.
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.
4)
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.
5)
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
sent 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.
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 provided 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 general 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 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.
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 persons. 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.
Contact Us: You may contact us regarding any question,
concern or matter pertaining to this Policy at:
Phone: 510-251-6000 or 800-782-8782
Website: spectrumcu.org/resources/contact-us
Email: Secure Email via Digital
Banking
Mail: P.O. Box 4107, Concord, CA 94524
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.