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Introduction
At Delta Community Credit Union (the "Credit Union") our first goal is to deliver sincere, personalized care and honest advice to members and be responsive to their financial needs. We see protecting your privacy as a differentiator, and we respect your privacy and commit to protect it through our compliance with this policy.
Please read this policy carefully to understand how we handle your information. If you do not agree with our policies and practices, please do not use our Website or Mobile App.
By accessing or using this Website or Mobile App, you agree to this privacy policy.
Scope
This policy describes the types of information we may collect from you or that you may provide when you visit deltacommunitycu.com (our "Website") or the Delta Community Credit Union Mobile App (our "Mobile App") and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- On this Website or Mobile App;
- In email, text, and other electronic messages between you and this Website or Mobile App;
- Through Credit Union mobile and desktop applications, applications you download from this Website, the Apple App Store or Google Play app store; and
- From our advertisements and applications that link to this policy.
It does not cover information collected by:
- Us to process or connected with a financial transaction, subject to our Privacy & Opt Out notice;
- Us offline or through any other means, including on any other website operated by the Credit Union or any third party; or
- Any third party, including any application or content linked to or accessed from the Website or Mobile App.
Updates
We may change this policy (see Changes to Our Privacy Policy). By using our Website or Mobile App after we make changes, you accept those changes, so please check the policy for updates from time-to-time.
Children Under the Age of 13
Our Website and Mobile App are not intended for children under 13 years of age. No one under age 13 may provide any information to the Website or Mobile App. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or Mobile App or register for Online Banking.
If we learn we have collected or received personal information from a child under 13 without parental consent, we will delete that information as permitted or required by applicable law. If you believe we might have any information from or about a child under 13, please contact us by email at privacy@deltacommunitycu.com, by mail at 3250 Riverwood Parkway, Atlanta, GA 30339, or by phone at 800-544-3328.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website and Mobile App, including information:
· By which you may be personally identified, such as name, postal address, email address, telephone number, social security number or financial information submitted via our Online Banking portal ("personal information");
· That is about you but individually does not identify you, such as browsing history including the website visited before visiting deltacommunitycu.com and after visiting deltacommunitycu.com, search history, information on a consumer's interaction with a website, application, or advertisement; and/or
· About your internet connection, the equipment you use to access our Website or Mobile App, and usage details.
We collect this information:
· From you when you provide it to us;
· Automatically as you navigate through the Website or Mobile App including, for example, usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
· From third parties, for example, our business associates.
Information You Provide to Us
Examples of the information we collect on or through our Website or Mobile App may include:
· Information that you provide by filling in forms on our Website or Mobile App, including information provided at the time of registering to use our Online Banking portal, contacting us with the help feature in the Online Banking portal, and using the "Refer-a-Friend" feature;
· We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website;
· Records and copies of your correspondence (including email addresses), if you contact us;
· Your responses to surveys that we might ask you to complete for research purposes;
· Details of transactions you carry out through our Website or Mobile App; and
· Your search queries on the Website.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website or Mobile App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
· Details of your visits, including traffic data, location data, logs, and other communication data and the resources that you access and use; and
· Information about your computer and internet connection, including your IP address, operating system, and browser type.
Delta Community works with third parties including Google to track access and use of our websites. For instance, Google Analytics provides us information on visits to our websites. In order to provide us with these analytical services, Google Analytics collects certain information related to your visits to deltacommunitycu.com including the following information:
• Pages visited and length of time spent on pages;
• Device ID information including IP address; and
• How you got here and where you went after visiting our site.
You can find information about Google Analytics privacy practices by accessing the Google Privacy Policy.
In addition to Google, we also work with advertising agencies such as H/L Agency to improve our web functionality and better understand your interests, so we can share meaningful information about our products and services with you.
We also may collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and Mobile App and to offer better service, including by helping us:
· Estimate our audience size and usage patterns;
· Store information about your preferences;
· Speed up your searches; and
· Recognize you.
The technologies we use for this automatic data collection may include:
· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website; and
· Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal information automatically, but we may link automatically collected information to personal information from other sources or that you provide to us.
Do Not Track Functions
Delta Community Credit Union recognizes the Global Privacy Control also referred to as GPC. We may honor other do not track browser signals, and we reserve the right to determine which do not track browser signals to honor at our discretion subject to applicable legal requirements.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
· To present our Website and Mobile App to you;
· To provide you with information, products, or services;
· To fulfill any other purpose for which you provide it;
· To provide you with notices about your account, including expiration and renewal notices;
· To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
· To notify you about changes to our Website, Mobile App or any products or services we offer or provide through them;
· To allow you to participate in interactive features on our Website and Mobile App;
· To enable you to conduct transactions during your online banking session;
· In any other way we may describe when you provide the information; and
· For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties' products and services that may be of interest to you. If you do not want us to use your information in this way, please see our Privacy and Opt-Out Notification.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy and our Privacy and Opt-Out Notification or other privacy documents and disclosures including those that may be targeted to a specific audience, i.e., residents of California:
· To our subsidiaries and affiliates;
· To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Credit Union's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Credit Union about our Website or Mobile App users is transferred;
· To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Privacy and Opt-Out Notification[GO2] ;
· To fulfill the purpose for which you provide it. For example, if you give us personal information to open an Online Banking account, we use it to open and maintain online access to your accounts;
· For any other purpose disclosed by us when you provide the information: and
· With your consent.
We may also disclose your personal information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
· To enforce or apply our Terms of Use, Online Banking Terms and Conditions[GO3] , Online Bill Pay Terms and Conditions [GO4] and other agreements, including for billing and collection purposes; and
· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Credit Union, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
The categories of personal information we may disclose include:
· Personal financial information as described in our Privacy and Opt-Out Notification[GO5] ;
· California residents’ personal information as described in our California Resident Notice at Collection[GO6] ;
· Personal information collected through promotions, such as contests or sweepstakes; and
· Personal information submitted using web forms.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
· Member information. Members may be excluded from information sharing with certain marketing business relationships. Click here for information on the Credit Union's Privacy and Opt-Out Notification;
· Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. We do not honor do not track browser settings necessary for us to process digital banking transactions;
· Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated third parties for promotional purposes, Members can opt-out by completing our Privacy and Opt-Out Notification; and
· Promotional Offers from the Credit Union. If you do not wish to have your email address/contact information used by the Credit Union to promote our own or third parties' products or services, Members can opt-out by checking the relevant box located on the Privacy and Opt-Out Notification. If we have sent you a promotional email, you may opt out of receiving future promotional emails using the links provided with the email.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website[GO7] .
Residents of certain states, such as California may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.
Accessing and Correcting Your Information
Members can review and update personal information by logging into the Online Banking portal or the Mobile App and clicking the Account Management tab[GO8] .
You may also request access to, correct or delete any personal information that you have provided to us in person at a branch office or by mail. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Members and residents of California may have additional personal information rights and choices. Please see the Privacy & Opt Out Notice [GO9] or Your State Privacy Rights for more information.
Deleting your information
For Delta Community members who would like to delete your mobile app account user profile, please reach out via email to MobileAppData@deltacommunitycu.com.[GO10] Please include in your email request these items: 1) Reason for Deleting Mobile Banking Profile, 2) First and Last Name, 3) Street Address, 4) City, 5) State, 6) ZIP Code, 7) Phone, 8) Email Address. Please note Delta Community may be required to retain certain information for record retention, legal and compliance considerations. Your request will be reviewed and a Delta Community representative will contact you for further verification within 7-10 business days.
Your State Privacy Rights
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. However, Delta Community is subject to financial services laws and regulations deferred to by many states.
California
California recognizes that financial services laws and regulations cover information relating to your financial transactions with us. However, California provides additional rights to California residents with respect to information we collect, access, use and disclose for other purposes, for example when California residents interact with public pages on deltacommunitycu.com. This section of our Online Privacy Policy offers information on our data practices with respect to non-financial transactions involving California residents. For information on our privacy practices with respect to financial information, review our Privacy and Opt-Out Notice.
Discrimination
Consistent with California law, we do not discriminate against California residents for exercising legal rights.
Mobile App
Additionally, California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Mobile App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@deltacommunitycu.com, write us at: 3250 Riverwood Parkway, Atlanta, GA 30339, attn. Legal or call 800-544-3328.
We invite California residents to reach out to us using the contact information [OG11] provided below with any requests, questions or concerns.
Delta Community’s California Resident Notice at Collection [OG12] describes our practices with respect to collecting certain information on California residents.
Data Security
We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers and is encrypted.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
The Delta Community Credit Union Online Banking portal uses encryption to secure account information sent between our server and your browser.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or Mobile App. We recommend that you use only secure channels to communicate sensitive or confidential information to us.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. Changes take effect when posted.
The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at:
(email) privacy@deltacommunitycu.com,
(mail) 3250 Riverwood Parkway, Atlanta, GA 30339, or
(toll-free) 800-544-3328.
