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IMPORTANT INFORMATION ABOUT THE PERSONAL DATA YOUR CREDIT UNION COLLECTS AND HOW IT’S USED
TruEnergy Federal Credit Union is owned by its members and run by a board of directors you elect. You can be confident that your financial privacy is a top priority of this credit union. We are required by law to give you this privacy notice to explain how we collect, use and safeguard your personal financial information.
At TruEnergy FCU, we respect your right to privacy and confidentiality. Safeguarding your assets and accounts and all financial personal information related to those accounts is our responsibility. Our policies and procedures were developed and implemented with that objective in mind.
To assure the continued privacy and confidentiality of your personal financial information, your credit union observes these practices and procedures:
Policies & Procedures
Information We Disclose
Your relationship is important to us, and we are committed to providing you with the best products and services possible. To do that, we collect non-public personal information from a variety of sources to keep you informed about the many financial services, products, and benefits available to you as a TruEnergy FCU member. We also collect information to comply with laws and regulations and to protect you against fraud. For example, we collect nonpublic information about you from some or all of the following sources: Information we receive from you on applications or other forms; information about your transactions with us, or others; information we receive from a consumer-reporting agency; information obtained when verifying information you provide on applications/forms. We do not disclose any nonpublic personal information about our members or former members to anyone, except as permitted by law. These disclosures typically include information to follow your instructions as you authorize, to conduct the operations of the credit union, or to protect the security of our financial records. To protect our members’ privacy, we only work with companies that agree to maintain confidentiality protections and limit the use of information we provide. We do not permit these companies to sell the information we provide to other third parties.
Non-Personal Information Automatically Collected & Stored
To improve the quality of our website services, we use Google’s Universal Analytics software to gather and temporarily store a variety of information about all of our website visitors. This will happen automatically whenever someone visits our website. The information we collect about every website visitor includes:
- The date and time of your visit to our website;
- The pages and documents that you view on our website;
- The URL of the website that you visited prior to ours;
- The name of the domain that you use to access the Internet (for example, Verizon.com, if you are using a Verizon online account, or stanford.edu, if you are connecting from Stanford University’s domain);
- The type and version of your web browser and operating system;
- Your location at the time of your visit, down to the city-level; and
- Other more technical information, including the HTTP status code, Windows NT code, number of bytes sent, number of bytes received, duration (in seconds) to fulfill the request, server port number addressed, and protocol version.
We do not use this information to identify individuals. We aggregate the information about all of our website visitors and use the aggregated information to improve our website and provide a better user experience to our visitors. We look at things like average duration of a visit, (the percentage of visitors who leave our site after viewing only one page), and the most frequently visited pages. The aggregated information is available only to web managers and other designated staff who need it to perform their official duties. It is retained only for as long as needed for proper analysis. The Google Analytics Privacy Policy is available to view here.
Links to Other Websites
Our website sometimes contains links to third party affiliates of TruEnergy FCU. TruEnergy FCU is not responsible for the privacy practices or content of any non-TruEnergy FCU website, and providing a link to a non-TruEnergy FCU website is not intended to be an endorsement of the website content. We encourage all of our members to review the privacy policy of every website you may visit.
Our Security Measures
TruEnergy FCU restricts access to nonpublic information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with Federal Regulations to guard your nonpublic personal information.
Right to Amend
TruEnergy FCU reserves the right to amend this disclosure at any time without prior notice. This disclosure amends existing agreements that the credit union has with you.
Biometric Information
SCOPE AND OVERVIEW
This policy outlines how TruEnergy Federal Credit Union, its vendors, and/or the licensor of the TruEnergy FCU’s member verification software processes biometric data collected from you for identity verification and fraud prevention purposes.
BIOMETRIC DATA DEFINED
As used in this policy, biometric data includes “biometric identifiers” and “biometric information”. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. As the term is used in this policy, the selfie photograph you upload to the software for use in the biometric algorithm is considered a “biometric identifier.” “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.
Disclosure and Authorization Policy
To the extent that TruEnergy FCU, its vendors, and/or the licensor of the TruEnergy FCU’s member verification software collect, capture, or otherwise obtain biometric data relating to a member, TruEnergy FCU must first:
- Inform each member that TruEnergy FCU, its vendors, and/or the licensor of the TruEnergy FCU’s member verification software are collecting, capturing, or otherwise obtaining the employee’s biometric data, and that the TruEnergy FCU is providing such biometric data to its vendors and the licensor of the TruEnergy FCU’s member verification software;
- Inform the member of the specific purpose and length of time for which the
member’s biometric data is being collected, stored, and used; and
- Receive consent by the member authorizing TruEnergy FCU, its vendors, and/or TruEnergy FCU’s member verification software to collect, store, and use the member’s biometric data for the specific purposes disclosed by the TruEnergy FCU, and for TruEnergy FCU to provide such biometric data to its vendors and the licensor of the TruEnergy FCU’s member verification software.
- TruEnergy FCU, its vendors, and/or the licensor of the TruEnergy FCU’s member verification software will not sell, lease, trade, or otherwise profit from employees’ biometric data; provided, however, that the TruEnergy FCU’s vendors and the licensor of the TruEnergy FCU’s member verification software may be paid for products or services used by TruEnergy FCU that utilize such biometric data.
This policy is intended to comply with all federal, state, and local laws.
PURPOSE FOR THE COLLECTION OF BIOMETRIC DATA
TruEnergy FCU, its vendors, and/or the licensor of TruEnergy FCU’s member verification software collect, store, and use biometric data solely for identity verification and fraud prevention purposes.
DISCLOSURE
TruEnergy FCU will not disclose or disseminate any biometric data to anyone other than its vendors and the licensor of the TruEnergy FCU’s member verification software providing products and services using biometric data without/unless:
- First obtaining member consent to such disclosure or dissemination;
- The disclosed data completes a financial transaction requested or authorized by the member;
- Disclosure is required by law or ordinance; or
- Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.
SECURITY
TruEnergy FCU shall use a commercially reasonable standard of care to store, transmit and protect from disclosure any biometric data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which TruEnergy FCU stores, transmits and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual or an individual’s account or property, such as genetic markers, genetic testing information, account numbers, PINs, driver’s license numbers and social security numbers.
RETENTION
TruEnergy FCU shall retain member biometric data only until, and shall request that its vendors and the licensor of TruEnergy FCU’s member verification software permanently destroy such data when, the first of the following occurs:
- The initial purpose for collecting or obtaining such biometric data has been satisfied, such as verification of member identity;
- Request of member to destroy the biometric data; or
- Within 30 days of member’s provisioning of biometric data.
CONTACT INFORMATION
If you have any questions about our use, storage, or security of your biometric data you can contact us at: [email protected] or 800-952-3999.
BIOMETRIC INFORMATION MEMBER CONSENT
As outlined in the “Biometric Information Privacy Policy”, I understand and consent to the collection, use, retention, storage, and/or disclosure or re-disclosure of data or images from biometric verification technology by TruEnergy FCU, its vendors, and/or the licensor of the TruEnergy FCU’s member verification software. I acknowledge that I have been given a copy of the Policy, or that the Policy has been made accessible to me, and I have had an opportunity to review it and request any additional information concerning the TruEnergy FCU’s procedures and safeguards for collecting, maintaining, using, disclosing, sharing, storing, and/or destroying this data.
This notice meets the notification requirements of the National Credit Union Administration regulation on privacy of consumer information, Part 716.
