Effective March 13, 2024

CONTENTS
 
Online Privacy and Cookie Notice
 
U.S. Consumer Privacy Notice
 
Important Privacy Choices for California Members
 
California Consumer Privacy Act (“CCPA”) Privacy Policy
 
PRIVACY POLICY
 
We have developed this Privacy Policy to address our collection, use and disclosure of confidential or personally identifiable information. This Privacy Policy applies to all persons and/or businesses who visit our websites as well as those who do business with us.  Credit Union of Southern California is committed to protecting the privacy of our members, customers and website visitors. References to "we," "us," and "our" refer to Credit Union of Southern California. References to "you," "your" and "yours" shall mean the members, customers and website visitors. References to “app” refers to our mobile applications that run on smartphones, tablets, and other devices, through which you will be able access Online Banking services. Unless otherwise stated herein, references to our website also include our Online Banking services available through our app.
 
The following provides a brief explanation of the contents of this Privacy Policy:
 

• Online Privacy and Cookie Notice.  The Online Privacy and Cookie Notice discloses how we collect, use, and share information from visitors to our website (www.cusocal.org) and users of our app (CU SoCal Mobile Banking) and Online Banking services. 
• U.S. Consumer Privacy Notice.  The U.S. Consumer Privacy Notice discloses how we collect, use, and share the personal information of individuals who apply for or obtain our financial products and services for personal, family, or household purposes as well as other associated individuals, such as joint account holders and account beneficiaries, pursuant to the federal Gramm-Leach Bliley Act (“GLBA”). 
• Important Privacy Choices for California Members.  Residents of California who have applied for or obtained our financial products and services for personal, family, or household purposes, may exercise their right to opt-out of our sharing of their personal information with other companies we do business with to provide financial products and services through this form, pursuant to the California Financial Information Privacy Act (“CalFIPA”).
• California Consumer Privacy Act (“CCPA”) Privacy Policy.  The CCPA Privacy Policy applies to residents of California to the extent that the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), applies to Credit Union of Southern California.  The specific personal information that we collect, use, and disclose relating to a California resident in different contexts covered by the CCPA will vary based on our relationship or interaction with that individual. For example, the CCPA Privacy Policy does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes (i.e., information subject to the GLBA and CalFIPA). For more information about how we collect, disclose, and secure information relating to these customers, please refer to the U.S. Consumer Privacy Notice. 

Online Privacy and Cookie Notice

This Online Privacy and Cookie Notice (“Online Privacy Notice”) describes Credit Union of Southern California’s online and mobile privacy practices and applies to our website (www.cusocal.org) and our mobile app (CU SoCal Mobile Banking) that run on smartphones, tablets, and other devices, and additional services that we offer which link to this Online Privacy Notice. 
 
By using this website or our mobile app, you agree to the terms and conditions of this Online Privacy Notice and consent to our online data collection activities as described in this Online Privacy Notice.
 
The terms “personal information” or “personally identifiable information” used in this Online Privacy Notice 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, and display/screen settings; how you interact with our website and app; 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 that does not identify individual consumers/customers.
 
INFORMATION WE COLLECT ONLINE – AND HOW WE COLLECT IT
 
You may visit our website 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 includes 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. We may also track browsing activities of members who have accounts with Credit Union of Southern California and who use online banking services. As part of our security procedures for members using our online banking to conduct account inquiries and transactions, we require personally identifiable information such as a login identification (login ID) and password.  We may use a cookie to authenticate your request.
 

1) Use of Cookies and Similar Tracking Technologies

 

The use of cookies and similar tracking technologies (including pixels or clear GIFs, tags, and we beacons) is a common internet practice.  Cookies are small text files containing small amounts of information which are downloaded to your computer, smartphone, tablet or other mobile device when you visit a website.  Cookies are useful in a number of ways, including allowing a site or mobile app you use to recognize your device, save your settings on a site or mobile app, facilitate navigation, display information more effectively and to personalize the user’s experience. Cookies are also used to gather statistical information about how sites and mobile apps are used in order to continually improve design and functionality and assist with resolving questions regarding the sites and mobile app.

 

     a. Attributes of Cookies

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.
 

2. Categories of Cookies

 
Below is a list of the types of cookies that may be used on our sites. We classify cookies into the following categories:
 
Strictly Necessary Cookies. These cookies are necessary for the sites to function and cannot be switched off in our systems. Without these cookies, the sites and mobile apps will not work properly. Examples include setting your privacy preferences, setting your language preferences or logging in a secured area requiring authentication. Strictly necessary cookies may also detect transmission errors or data loss or distribute network traffic across different servers to ensure accessibility.  You can set your browser to block or alert you about these cookies, but that will cause some parts of the site to not work.
 
Targeting Cookies.  These cookies may be set through our site by our advertising partners.  They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.  They don’t store directly personal information but may be based on uniquely identifying your browser or internet device.  By opting out of targeting cookies, 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.
 
Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve performance of our site.  They help us know which pages are most and least popular and see how visitors move around the site.  All information these cookies collect is aggregated and therefore do not personally identify the visitor.  If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance. 
 
Functional Cookies. These cookies enable our site to provide enhanced functionality and personalization.  They may be set by us or by third party providers whose services we have added to our pages.  If you do not allow these cookies then some or all of these services may not function property. 
 

3. How to Control and Delete Cookies

 

1. Using Your Browser

 
Many of the cookies used on our website 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. 
 

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. Behavioral Advertising on Third-Party Websites

 
Online activity data collected on our website or apps may be used to advertise our products and services that may be of interest to you on third party websites. Our service providers that deliver these advertisements are subject to their own privacy policies. To explore options for opting out of behavioral advertising, visit http://optout.aboutads.info/ or click on the AdChoices icon in an ad and follow the instructions. You may also use the Network Advertising Initiative's (NAI) Opt-Out Tool by visiting https://optout.networkadvertising.org/?c=1.   Furthermore, you may download the Google Analytics opt-out plug in, available at https://tools.google.com/dlpage/gaoptout/, to prevent your data from being collected and used by Google Analytics.     Moreover, there may be other tools provided by the publishing platform to enable you to opt-out. Opting out relies on information in the unique cookies placed on your web browser by our service providers, so if you delete cookies, use a different device, or change web browsers, you may need to opt out again. Additionally, we may partner with websites like Google and Yahoo to display ads to you based on search terms you use on those websites. Please review the privacy policies of those websites for instructions on how to limit these ads. Please note that you may still receive general online advertising from us even after you adjust your ad preferences with certain web search engines or opt out of online advertising through AdChoices or the NAI tool. Such advertising, however, should not be based on online activity data or search term information. 
 
However, since we do not own or control these third-party resources, we cannot ensure that you will stop receiving our advertisements by using these tools or that such advertisements will not be based on online activity data or search term information, and we do not guarantee the functionality or availability of such third-party tools.  While we work with vendors and service providers who are contractually obligated to comply with our policies to protect information and to comply with all applicable laws regarding the collection, safeguarding, processing and disclosure of personal information, such vendors and service providers are solely responsible for cookies, cookie tracking and your choices for managing cookies.
 

4. Cookie Consent Tool

 
You may also opt-out of cookies by adjusting your cookie preferences through our cookie consent tool, which may be accessed through our cookies banner when first vising our site by clicking “Cookies Settings” and “Confirming My Choices” after browsing through various tabs that describe the various types of cookies that run on our site.   Strictly necessary cookies cannot be disabled, nor can the tool be used to block cookies on third party websites linked from our website.  Please note that while your opt-out choices may be effective on the specific device and browser you use when you opt-out, it may not be effective on other devices or browsers that you may subsequently use to visit our website, and you may need to use the consent tool feature again when visiting our website from such other browsers or devices. 
 
You can access the cookie consent tool anytime from this link.
 

5. Third Party Website Cookies That We Cannot Control

 
When using our website, you may be directed to other websites for such activities 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 website. 

2) Location Data  

When allowed by you, our mobile 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.

3) IP Addresses  

If you log on to our online banking page, you pass through a "firewall" used for security purposes and the Internet Protocol (IP) address associated with the computer you are using may be identified. The IP address does not identify you personally. In certain instances, it may also obtain other information about your computer 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.

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 provide 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 the U.S. Consumer Privacy Notice. 
With respect to other information that we collect from you online, which includes personal information as well as online activity data that does not personally identify you or your household, we use such information for a variety of reasons, including:

• to present our website and its 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;
• 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 non-personally identifiable online activity data to third parties for only for 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
 
App Permissions: Depending on your device or app permission settings, the app may have access to the following information from your mobile device: Contacts (may have access to your contact information), location (may include precise or approximate location), stored information and photos/media/files (the app may be able to read, modify, or delete the contents of your USB storage), camera (may allow the app to take pictures and videos), Wi-Fi connection information (view your Wi-Fi connections to connect and disconnect from Wi-Fi), phone (may directly call phone numbers), and other information (for example, the app may be able to receive data from the Internet, prevent your device from sleeping, identify your network connections, and obtain full network access).
 
These app permission settings allow you to access or use certain features within the app. For example, in order to locate the nearest branch to you, the app may need access to your precise location. You may change your app permission settings. By changing your app permission settings, you may affect your ability to access or use certain features on the app. Additionally, you may be able to log into the app using your device’s log in features such as using a passcode or your fingerprint. These device log in features are facilitated through your device and we have no control over such features, which you can change by accessing your device settings and preferences.
 
Confirm Your Information Is Accurate: Keeping your account information up-to-date is important. If you are an enrolled in online services, CU SoCal Mobile Banking, or electronic banking, you may review and maintain your information by logging in with your username and password. You may also contact us at 866 CU SoCal/866 287-6225, by writing to us at CU SoCal, P.O. Box 76000 Anaheim, CA 92809 or by visiting us in person at any CU SoCal branch.
 
Security: Protecting the confidentiality, security and protection of your personal information and financial information is our highest priority.  We value your trust, and we understand that handling of 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 website, online services, electronic banking or CU SoCal Mobile Banking, electronic banking, Membership, loan application, and mortgage loan websites 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 free 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 Credit Union of Southern California 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: The website, online services, electronic banking or CU SoCal 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 the website 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.
Chat Sessions: Please note that chat sessions may be monitored and/or recorded for quality assurance.  You agree and consent to such monitoring and recording through your continued use of chat. If you prefer another method of communication, please feel free to contact us via the additional options provided in the “Contact Us” link on our website or visit one of our branches for further assistance.
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. 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 or website 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 period as necessary or advisable to preserve legal claims and defenses.

 
Contact Us: If you have any questions regarding this Policy, call us at 866 CU SoCal/866 287-6225 or write to us at CU SoCal, P.O. Box 76000 Anaheim, CA 92809.
 
Updates to this Policy: From time to time, we may change this Online Privacy Notice. The effective date of this Online Privacy Notice, 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 the website, online services, electronic banking or CU SoCal Mobile Banking following these changes means that you accept the revised Online Privacy Notice.

  Rev. March/13/2024

This California Consumer Privacy Act Privacy Policy explains how we collect, share, use, and protect your personal information through your online and offline interactions with us. This CCPA Disclosure applies to residents of California to the extent that the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), applies to Credit Union of Southern California (also “we”, “us” and “CU SoCal”).  As used in this Privacy Policy, “personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  However, personal Information does not include: (i) publicly available information; (ii) deidentified or aggregated consumer information; or (iii) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”) and the Gramm-Leach-Bliley Act (“GLBA”).

The specific personal information that we collect, use, and disclose relating to a California resident in different contexts covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this CCPA Disclosure does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes (i.e., information subject to the GLBA). For more information about how we collect, disclose, and secure information relating to these customers, please refer to our U.S. Consumer Privacy Notice. We may use the information described below for any of the purposes described in this CCPA Disclosure or for our business, security, or operational purposes compatible with the context in which the personal information was collected, unless limitations are listed in this CCPA Disclosure or described elsewhere at the time of collection of the information.

I.          CATEGORIES OF INFORMATION WE COLLECT
In the preceding 12-months, we have collected the following categories of personal information (please note that some categories overlap):
 

Category	Examples
A. Identifiers	A real name or alias; postal address; signature; home phone number or mobile phone number; membership number, credit card number, debit card number, or other financial information; physical characteristics or description; email address; account name; Social Security number; driver’s license number or state identification card number; passport number; or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under state or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information	Records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies.
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity	Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data	Physical location or movements. For example, city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and, with your permission in accordance with your mobile device settings, precise geolocation information from GPS-based functionality on your mobile devices.
H. Sensory data	Audio, electronic, visual, or similar information.
I. Professional or employment-related information	Current or past job history, performance evaluations, disciplinary records, workplace injury records, disability accommodations, and complaint records; Emergency contact information, such as the name, phone number, address and email address of another person in the context of having an emergency contact on file; Personal information necessary for us to collect and retain to administer benefits for you and another personal relating to you (e.g., your spouse, domestic partner, and dependents), such as their name, Social Security Number, date of birth, telephone number, email, and address.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Educational records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information	Profile reflecting a person’s preference, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
L. Sensitive Personal Information	A consumer’s social security, driver’s license, state identification card, or passport number; A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; A consumer’s precise geolocation; A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; A consumer’s genetic data; The processing of biometric information for the purpose of uniquely identifying a consumer; Personal information collected and analyzed concerning a consumer’s health; Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation; and immigration or citizenship status.

 
For purposes of the CCPA, “personal information” does not include:

• Publicly available information.
• De-identified information that cannot reasonably be used to identify you or your household.
• Aggregated consumer information that relates to a group or category of consumers, from which consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device.
• Information excluded from the CCPA’s scope like personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

II.        CATEGORIES OF SOURCES OF INFORMATION WE COLLECT
We obtain the categories of personal information listed above from the following categories of sources:
 

• Directly from consumers or their agents. For example, from forms you complete, when you perform transactions, and when you purchase products or services.
• Indirectly from consumers or their agents. For example, when you use your debit or credit cards, when you make deposits or withdrawals to/from your accounts, or when you pay your bills.
• Directly and indirectly from activity on our website or our mobile applications. For example, from submissions through our website, application portals, or website usage collected automatically.
• From third-parties, such as credit reporting agencies, government agencies, law enforcement agencies, and service providers.

III.       HOW WE USE YOUR PERSONAL INFORMATION
We may use or disclose personal information we collect for one or more of the following operational or other notified purposes (“business purposes”):
 

• To fulfill or meet the reason for which the information is provided. For example, if you apply for a loan, we use the information in your loan application to evaluate your credit request and grant you the loan if approved.
• To provide you with information, products, or services that you request from us.
• To provide you with email alerts, event registrations, or other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, and analysis to improve our products and services and for developing new ones.
• To protect the rights, property, or safety of us, our employees, our members, or others.
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us is among the assets transferred.
• As otherwise permitted under law.

 
With respect to your personal information that is deemed “sensitive personal information” under the CCPA, we do not use or disclose it for any purpose other than, as reasonably necessary and proportionate, for the following purposes:
 

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods and services. 
• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
• To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
• To ensure the physical safety of natural persons.
• For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside of your current interaction with us.
• For our service providers or contractors to perform services on our behalf, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf; provided, however, that the use of your sensitive personal information is reasonably necessary and proportionate for this purpose.
• To verify or maintain the quality or safety of a service or device that is owned, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured for, or controlled by us; provided, however, that the use of your sensitive personal information is reasonably necessary and proportionate for this purpose.
• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about you.

IV.     HOW WE SHARE AND DISCLOSE PERSONAL INFORMATION
In addition to the specific situations discussed elsewhere in this CCPA Disclosure, we may disclose your personal information in the following situations:
 

• Service Providers.  We may share your information with service providers.  Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, process payments, assist in the fulfillment of services, and help us market our own products and services.
• Joint Marketing Partners.  We may share your information with other companies to offer you co-branded financial products and services. 
• Advertising Networks.  We may share your information with advertising networks such as Google and Facebook to help deliver our advertisements to you as you are browsing online.
• Compliance with Laws and Other Lawful Uses.  We may disclose information to law enforcement agencies and other government entities or private parties in litigation in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws.  We may also share your information with this parties to establish or exercise our rights, to defend against a claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.  We may also disclose your personal information with our acquisition or merger partners in the event of an acquisition or merger.  Furthermore, we may disclose your personal information as permitted by applicable law.  All of the categories of personal information we collect from you may disclosed for this purpose.
• Your Consent.  All the categories of personal information we collect from you may be disclosed to third parties with your consent or direction.

In addition to the information above, California law requires that organizations disclose whether the specific categories of personal information defined in the CCPA have been disclosed to third parties for a “business purpose,” or “sold” or transferred for “valuable consideration, or “shared” for purposes of cross-context behavioral advertising.  The table below indicates which of these specified categories we may collect and transfer in a variety of contexts.
 

CATEGORY OF PERSONAL INFORMATION	CATEGORY OF RECIPIENTS (FOR BUSINESS PURPOSE)	CATEGORY OF RECIPIENTS (FOR “SALE” OR “VALUABLE CONSIDERATION”	CATEGORY OF RECIPIENTS (CROSS-CONTEXT BEHAVIORAL ADVERTISING)
Identifiers such as name, address, unique personal identifier, email address, or account name.	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Advertising networks.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
Protected classification characteristics under state or federal law	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
Commercial information	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
Biometric information	Service providers; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
Internet or other similar network activity	Service providers; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent	Not sold.	Advertising Networks
Geolocation data	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
Sensory data	Service providers;  Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
Professional or employment-related information	Service providers;  Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
Non-public education information	Service providers;  Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
Inferences drawn from other personal information	Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared.
Sensitive personal information	Service providers; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent.	Not sold.	Not shared

 
V.YOUR RIGHTS AND CHOICES
This section describes your rights and choices regarding how we collect, share, use, and protect your personal information, how to exercise those rights, and limits and exceptions to your rights and choices.
 

1. Exceptions

 
The rights and choices in this Section do not apply:
 

• If you are not a California resident;
• If we collected personal information covered by certain financial sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) and/or California Financial Information Privacy Act (“CFIPA”). How we collect, share, use, and protect your personal information is covered under such laws instead of the CCPA; or
• To aggregate consumer information; or
• To deidentified personal information; or
• Publicly available personal information.

 

2. Right to Know

 
If the above exceptions do not apply, and you have not made this request more than twice in a 12- month period, you have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your request and verify that the request is coming from you or someone authorized to make the request on your behalf, we will disclose to you or your representative:
 

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting, sharing or selling that personal information, as applicable.
• The categories of third parties to whom we disclosed, shared or sold the personal information, as applicable.
• The specific pieces of personal information we collected about you in a form that you can take with you (also called a “data portability request”).

 

3. Right to Delete

 
You have the right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
 

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
2. Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
3. Debug to identify and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
5. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you previously provided informed consent;
6. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; or
7. Comply with a legal obligation.

 

4. Right of Correction

You have the right to request correction of any personal information that we retain about you that is incorrect.  We generally rely on you to update and correct your personal information. 

      e.Exercising Access, Data Portability, Deletion and Correction Rights
To exercise the access, data portability, deletion and correction rights described above, you or your authorized agent may submit a verifiable consumer request to us by any of the following methods:

• Calling 866 CU SoCal (866-287-6225).
• Submitting a CCPA Submission Form  available via this link.
• Email to privacy@cusocal.org.  Attach a completed CCPA Submission Form with your email, and do not include any sensitive personal information with your request.
• Mail your request to Credit Union of Southern California, Attn: Privacy Department, P.O. Box 200, Whittier, California 90608.  Include a completed CCPA Submission Form with your request, and do not include any sensitive personal information with your request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
 
When we receive a verifiable request from your authorized agent we may require:
 

1. Submission of a written document signed by you with your permission for the authorized agent to submit a verifiable request on your behalf and require the authorized agent to verify its own identity to us; or
2. You may directly verify with us that you have authorized the agent to submit the request.

 
We will not require either of the above if the authorized agent provides a copy of a power of attorney pursuant to California Probate Code sections 4121 to 4130 and we are able to verify the authorized agent’s identity. 
 
We will deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf and cannot verify their own identity to us.
 
We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response to the mailing address of record according to our files.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hinderance. 
 
The response we provide will also explain the reasons we cannot comply with a request, if applicable.  We do not charge a fee to process or respond to your verifiable consumer request.

     f.Right of Non-Discrimination
We will not discriminate against you for exercising any of your rights in this Disclosure and under applicable laws. Unless permitted by law, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price for goods or services or a different level or quality of goods or services.

     g.Opt-Out Rights Regarding Sale of Personal Information or Sharing Personal Information for Cross-Context Behavioral Advertising
 
It is not our policy to sell personal information and we have not done so in the preceding 12-month period.
 
In the preceding 12-months, we have not shared your personal information to third-parties for cross-context behavioral advertising purposes.
 
To exercise the right to opt-out of the sale or sharing of your personal information for cross-context behavioral advertising purposes, you (or your authorized representative) may opt-out via the following link:
DO NOT SELL OR SHARE MY PERSONAL INFORMATION
 
If we receive an opt-out preference signal in a format commonly used and recognized by businesses, we will accept the signal as a valid request to opt-out of sale/sharing for the particular browser or device from which the signal was sent, and if we are able to identify you from your browser or device, we will accept the signal as an opt-out of sale/sharing for your personal information as well.  In most instances, we will not be able to identify you from your browsers or device, so if you would like to opt-out of sale/sharing of your personal information that may occur offline, please opt-out through the above DO NOT SELL OR SHARE MY PERSONAL INFORMATION link, through which we will ask for additional information to identify you.
 
VI.CHANGES TO THIS DISCLOSURE
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Disclosure, we will post an updated Privacy Policy on our website and mobile application. 

VII.CONTACT INFORMATION
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights, call 866 CU SoCal (866-287-6225), email us at privacy@cusocal.org or mail us at Credit Union of Southern California, Attn: Privacy Department, P.O. Box 76000, Anaheim, California 92809.