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California Consumer Privacy Act (CCPA)

Introduction

SCE Federal Credit Union (“SCE FCU”) 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 notice explains how we collect, use, and disclose personal information about California residents. It supplements SCE FCU’s Privacy Policy, Privacy Notice and Online Privacy Policy by providing you with information about your rights under the California Consumer Privacy Act (CCPA).

Categories of Personal Information we collect

We collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”).

The Personal Information we collect, use, or disclose about a specific California resident will vary and depend on our relationship and interaction with you. Here are the specific categories of personal information we collect based on the products and services you access or use:

  • Personal identifiers, including those listed in other California statutes such as: full name, alias, address, unique personal identifier, online identifier IP address, email, account name, Social Security number, driver’s license number, passport number, other government-issued ID, etc.
  • Any of the expanded categories of personal information in Calif. Civil Code §1798.80(e) for example: signature, insurance policy number, employment, employment history, bank account number, credit card number, debit card number or any other financial information.
  • Characteristics of protected classes under California or federal law, such as sex, marital status, nationality, citizenship, military or veteran status.
  • Purchase information, including records of personal property, products or services purchased, obtained, or considered, or related histories or tendencies.
  • Biometric information, such as fingerprints, facial scans, or voice recordings.
  • Internet or electronic activity information, such as browsing and search history, or interactions with our websites, applications, or advertisements.
  • Geolocation data, including physical location or movements based on internet activity or website interaction.
  • Audio, electronic, visual, thermal, olfactory, or similar information.
  • Professional or employment-related information (current or past job history, title, salary, references).
  • Education information not publicly available.
  • Inferences drawn from any of the above information used to create a consumer profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

Sources of Personal Information

The following outlines the categories of sources from which we collect personal data.

  • We obtain personal information directly from you or your representatives when you or they conduct business with SCE FCU. For example, you provide information (including personal documents) to us when applying for membership, loans and other products and services.
  • Information is also indirectly obtained from you in the course of you using added services, such as by use of your debit or credit card, deposits or withdrawals to your accounts, or paying your bills.
  • We collect personal information when you visit our any of our websites or use any of the features or resources available online. We can identify when and how you have connected to our site. Your device and browser may automatically disclose information such as device type, operating system, browser type, or IP address.
  • We receive your personal information from third parties that interact with us in connection with the products and services we provide, as well as interactions related to obligations required by law. For example, we may obtain information as needed from consumer-reporting agencies, credit bureaus, government agencies, law enforcement authorities and other service providers.
  • We collect certain information from your activity on our website activity on our website (insert website address) and your use of applications on your mobile device.  We may collect your IP address, device and advertising identifiers, browser type, operating system, Internet service provider (“ISP”), pages that you visit before and after visiting our website, the date and time of your visit, information about the links you click and pages you view on our website, and other standard server log information.  We may also collect your mobile device’s GPS signal, or other information about nearby Wi-Fi access points and cell tower.

The Role of Cookies and Other Online Tracking Technologies

We, or our service providers, and other companies we work with may deploy and use cookies, web beacons, local shared objects and other tracking technologies for various purposes, such as fraud prevention and to promote our products and services to you. Some of these tracking tools may detect characteristics or settings of the specific device you use to access our online services.

“Cookies” are pieces of information that are stored directly on your computer, smartphone or other internet access device. Browser cookies are assigned by a web server to the browser on your device. When you return to a website you have visited before, your browser gives this data back to the server. When you visit the Website, we may use cookies and information gathered through their use to personalize your experience with us based on the products, services and other interactions you have with us. Information gathered through the use of cookies may be used to make offers to you via online ads, email, U.S. mail or telephone, subject to the privacy preferences you have on file with SCE FCU. Cookies we use do not contain or capture unencrypted personal information.

The browsers of most computers, smartphones and other internet access devices are set up to accept cookies. You can refuse to accept these cookies through your browser settings. You will need to manage your cookie settings for each device and browser you use. If you choose to reject cookies, you may not be able to use the full functionality of the Website. For example, if we are not able to recognize your device, you will need to answer a challenge question each time you log on. You also may not receive customized advertising or other offers from us that may be relevant to your interests and needs.

Clear GIFs, pixel tags or web beacons – which are typically one-pixel, transparent images located on a webpage or in an email or other message – or similar technologies may be used on our sites and in some of our digital communications (such as email or other marketing messages).  They may also be used when you are served advertisements, or you otherwise interact with advertisements outside of our online services.  These are principally used to help recognize users, assess traffic patterns and measure site or campaign engagement.

“First party” cookies are stored by the domain (website) you are vising directly. They allow the website’s owner to collect analytics data, remember language settings, and perform useful functions that help provide a good experience. “Third-party” cookies are created by domains other than the one you are visiting directly, hence the name third-party. They may be used for cross-site tracking, retargeting and ad-serving. We also believe that cookies fall into the following general 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.

Use of Information

The personal information we collect is used for one or more of the following everyday business purposes:

  • To fulfill our business purpose and provide you with the service(s) and/or product(s) for which the personal information was collected this includes processing account transactions and activities related to ongoing account maintenance (such as providing account statements, online banking access, customer service, collections, and account notifications);
  • To support our operations, including risk, legal, and regulatory compliance requirements as required by law;
  • To communicate via any means (including email, telephone, text message, or in person) with you about products, services, and events offered by SCE FCU and others, as well as provide news and information we think will be of interest to you;
  • To respond to your comments, questions, and customer service requests, as well as to send you support notices, updates, security alerts, and administrative messages (such as changes to our terms, conditions, and policies);
  • To prevent fraud by monitoring activity to detect, investigate, and prevent potentially fraudulent transactions and other illegal activities, as well as to protect the rights and property of SCE FCU and our members;
  • To monitor and analyze trends, usage, and activities in connection with our products and services;
  • To audit the quality and efficacy of our work for compliance, controls, and other risk management;
  • To improve our products and services by identifying issues with existing products and services, enhancing existing products and services, and creating new products and services;
  • To carry out any other purpose described to you at the time the information was collected.

Categories of Third Parties with Whom Personal Information is Shared

The categories of third parties with whom we share personal information is based on, among other things, our relationship and interaction with you. The information below lists the categories of third parties with whom we share personal data in different context.

  • Outside companies or organizations that host, maintain, manage, or provide other services to us in relation to our products and services;
  • With third parties that provide financial products and services to our members such as our card processors, online banking, or bill pay provider;
  • Companies related by common ownership or control. They can be financial and nonfinancial companies. SCE FCU’s affiliates include financial companies such as Community Mortgage Funding and Member Advantage Insurance Services;
  • Government agencies, which include cooperating with public authorities and law enforcement, to respond to a lawful request, or to provide information we believe is important;
  • For other legal reasons, such as to monitor compliance with and enforce our terms and conditions, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, to protect against potential or actual fraud, money laundering, terrorism, or other illegal activity, and for risk management purpose;
  • We may also share information with outside accountants, auditors, lawyers and other outside professional advisors to SCE FCU, subject to confidentiality;
  • Outside companies or organizations, including credit bureaus and other consumer reporting agencies for routine and required reporting.

Sale of Personal Information

SCE FCU does not sell your personal information (this includes personal information of minors under the age of 16). However, SCE FCU may share personal information as necessary to fulfill our everyday business purposes and to comply with federal law.

Rights Under CCPA

If you are a California resident, you have the right to request up to two times during any 12-month period that we:

  1. Disclose to you the following information covering the 12-month period prior to your request:
    1. The categories of Personal Information we have collected about you and the categories of sources from which we collected the Personal Information;
    2. The purpose for collecting Personal Information about you;
    3. The categories of third parties to whom we disclosed Personal Information about you, and the categories of Personal Information disclosed;
    4. The specific pieces of Personal Information we collected about you; and
  2. Delete Personal Information we collected from you, unless CCPA recognizes an exception; and
  3. Be free from unlawful discrimination against you for exercising your rights under the CCPA.

Responding to Requests

We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. For security purposes requests for specific pieces of Personal Information will require additional information to verify your identity.

If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.

There may be instances where, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify you have the authority to make a request on behalf of another individual.

Additionally, we will not honor your request if providing the Personal Information would adversely affect the privacy rights of others or where the Personal Information we maintain about you is not subject to the CCPA’s access or deletion rights.

We will advise you in our response if we are not able to honor your request. We will not provide social security numbers, driver’s license numbers or government-issued identification numbers, financial account numbers, health care or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft, or fraud, or unreasonable risk to data or systems and network security. In these cases, we may refer you to an SCE FCU branch location.

We may decline to honor a request to delete Personal Information to the extent that CCPA allows; we may not comply with the deletion request if the Personal Information is maintained for lawful purposes, such as providing you a product or service you requested or complying with federal, state, or local law.

We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.

Any response we provide will only cover the 12-month period preceding the verifiable consumer request. If applicable, the response will also explain the reasons we cannot comply with a request.

How to Make Requests

If you are a California resident, you can make a request by:

  1. Contacting us at 800.866.6474; or
  2. Submitting your request at California Consumer Privacy Act Request

Changes to This Notice

We may change or update this Notice periodically. When we do, we will post the revised Notice on this webpage indicating when the Notice was “Last Updated.”