California Consumer Privacy Act Disclosure
Last updated January 1, 2020
Your privacy is important to us. This California Consumer Privacy Act Disclosure explains how Affinity Federal Credit Union (“Company,” “we,” or “us, “Affinity”, “AFCU”) collect, use, and disclose personal information relating to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA defines “resident,” to include (1) every individual (a natural person not a business entity) who is in the State for other than a temporary or transitory purpose; and (2) every individual who is domiciled in the State, but is outside the State for a temporary or transitory purpose. All other individuals are nonresidents. If an individual acquires the status of a resident by virtue of being physically present in the State for other than temporary or transitory purposes, this person remains a resident even though temporarily absent from California. If, however, this person leaves California for other than temporary or transitory purposes, this person is no longer deemed a resident. This notice is provided pursuant to the CCPA.
Under the CCPA, ‘Personal Information’ is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular consumer or household. The CCPA, however, does not apply to certain information, such as information that is collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach Bliley Act (“GLBA”), and implementing regulations, or the California Financial Information Privacy Act (“CFIPA”).The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based upon our relationship or interaction with that individual. For example, for more information about how we collect, disclose, share, and secure information, please refer to AFCU’s Privacy Notice.
Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or elsewhere.
Collection and Disclosure of Personal Information
In the past 12 months, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents covered by this disclosure:
- Identifiers, such as name and government-issued identifier (e.g., Social Security number);
- Personal information, as defined in the California safeguards law, such as contact information and financial information;
- Characteristics of protected classifications under California or federal law, such as sex and marital status;
- Commercial information, such as transaction information and purchase history;
- Internet or network activity information, such as browsing history and interactions with our website;
- Geolocation data, such as device location and Internet Protocol (IP) location;
- Audio, electronic, visual and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employer;
- Education information, such as student records and directory information that is not publicly available; and
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
The categories of sources from whom we collected this Personal Information are:
- Directly from a California resident or the individual’s representatives
- Service Providers, Consumer Data Resellers, and other third parties
- Public Record Sources (Federal, State or Local Government Sources)
- Information from our Affiliates
- Website/Mobile App Activity/Social Media
- Information from Client Directed Third Parties or Institutions representing a Client/Prospect
The categories of third parties to whom we disclosed Personal Information for our business purposes described in this privacy disclosure are:
Affiliates and Subsidiaries of AFCU:
- Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing, and marketing research activities
- Partners and Third Parties who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, notaries and auditors, who promote the credit union and its financial services, and products to members and other prospective buyers
- Other Third Parties who enable members to conduct transactions online and via mobile devices, support mortgage and fulfillment services, vehicle loan processes and aggregators (at the direction of the member)
- Government Agencies as required by laws and regulations
Use of Personal Information
In the past 12 months, we have used Personal Information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying member information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Short-term, transient use where the information is not disclosed to a third party and is not used to build a profile or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
- Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.
- Debugging to identify and repair errors that impair existing intended functionality.
- Undertaking internal research for technological development and demonstration.
- Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions)
Sale of Personal Information
Affinity does not sell Personal Information. In the past 12 months, we have not “sold” any Personal Information subject to the CCPA, including Personal Information of minors under the age of 16. For purposes of this Disclosure, the “sale” of Personal Information means selling, renting, releasing, disclosing, transferring, making available, or otherwise communicating a consumer’s personal information to a third-party or another business for monetary or other valuable consideration.
Rights under the CCPA
If you are a California resident, you have the right to:
- Request we disclose to you free of charge the following information covering the 12 months preceding your request:
a. the categories of Personal Information about you that we collected;
b. the categories of sources from which the Personal Information was collected;
c. the purpose for collecting Personal Information about you;
d. the categories of third parties to whom we disclosed Personal Information about you and the categories of e. Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
the specific pieces of Personal Information we collected about you;
- Request we delete Personal Information we collected from you, unless the CCPA recognizes an exception;
- Opt out of the sale of Personal Information; and
- Be free from unlawful discrimination for exercising your rights under the CCPA.
We will acknowledge receipt of your request within 45 days as long as we are able to verify your identity. Requests for specific pieces of Personal Information may require additional information to verify your identity.
If you submit a request on behalf of another person, we will require proof of authorization and verification of identity directly from the person for whom you are submitting a request.
In some instances, 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 that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that 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.
Ways to Exercise Your Rights under the California Consumer Privacy Act
If you are a California resident, you may submit a request by:
- Completing an online
- Calling 800-325-0808
Questions or Concerns
You may contact us with questions or concerns about this Disclosure and our practices by:
Emailing us at: Regulatory Compliance Requests (reference Personal Information Request in the subject line)
Changes to This California Consumer Privacy Act Disclosure
We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.