Online Privacy Policy for Cabrillo Credit Union

Last updated: December 13, 2023

This Privacy Policy outlines our practices regarding the collection, use, and disclosure of your information when you use the Cabrillo Credit Union Service. It also informs you about your privacy rights and legal protections. By utilizing the Service, you agree to the terms described in this Online Privacy Policy.

Interpretation and Definitions

Interpretation

Terms with initial capitalization have specific meanings defined under the following conditions. These definitions apply whether the terms appear in singular or plural form.

Definitions

For the purposes of this Online Privacy Policy:

• Account: A unique account created for you to access our Service or parts of our Service.
• Affiliate: An entity that controls, is controlled by, or is under common control with a party. "Control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for the election of directors or other managing authority.
• Application: Refers to Cabrillo Credit Union’s mobile and online banking applications, and all ancillary services accessible within the Application.
• Credit Union: Refers to Cabrillo Credit Union, located at 3710 Ruffin Rd, San Diego, CA 92123.
• Country: Refers to California, United States.
• Device: Any device that can access the Service, such as a computer, mobile phone, or digital tablet.
• Personal Data: Any information relating to an identified or identifiable individual.
• Service: Refers to the Application.
• Service Provider: Any natural or legal person processing data on behalf of the Credit Union. This includes third-party companies or individuals employed by the Credit Union to facilitate the Service, provide the Service, or assist in analyzing how the Service is used.
• Usage Data: Data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (e.g., the duration of a page visit).
• You: The individual accessing or using the Service, or the Credit Union, or another legal entity on whose behalf such individual is accessing or using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using our Service, we may request personally identifiable information, including but not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City

Usage Data

Usage Data is collected automatically and may include information such as:

• Device's Internet Protocol address (IP address)
• Browser type and version
• Pages visited on our Service
• Date and time of visit
• Time spent on pages
• Unique device identifiers and other diagnostic data

When accessing the Service via a mobile device, additional information may be collected, such as the type of mobile device, unique device ID, mobile IP address, mobile operating system, mobile internet browser type, and other diagnostic data.

Information Collected while Using the Application

While using our Application, and with your prior permission, we may collect:

• Location information (e.g., Card Controls App)
• Information from your device's phone book or contacts (used with Zelle™)
• Pictures and other information from your device's camera and photo library (used for Mobile Deposit)

This information is utilized to provide features of our Service and may be uploaded to the Credit Union's servers or a Service Provider's server, or stored on your device. You can enable or disable access to this information at any time through your device settings.

Use of Your Personal Data

The Credit Union may use Personal Data for the following purposes:

• To provide and maintain our Service, including monitoring usage.
• To manage your Account: Your registration as a user of the Service allows access to different functionalities.
• For contract performance: Development, compliance, and undertaking of purchase contracts or other contracts through the Service.
• To contact you: Via email, telephone calls, SMS, or other electronic communication, including push notifications, for updates or informative communications related to the Service.
• To provide news, special offers, and general information about goods, services, and events similar to those you have purchased or inquired about.
• To manage your requests: To attend and manage your requests.
• For business transfers: Evaluation or conduct of mergers, divestitures, restructuring, reorganization, dissolution, or other sale or transfer of assets.
• For other purposes: Data analysis, identifying usage trends, assessing promotional campaign effectiveness, and improving our Service, products, services, marketing, and user experience.

We may share your personal information in the following situations:

• With Service Providers: To monitor and analyze Service usage, and to contact you.
• For business transfers: In connection with mergers, sales, financing, or acquisition of all or part of our business.
• With Affiliates: With Our parent Credit Union and any subsidiaries or companies under common control.
• With business partners: To offer certain products, services, or promotions.
• With other users: When sharing personal information or interacting in public areas with other users.
• With your consent: For any other purpose with your explicit consent.

Retention of Your Personal Data

The Credit Union will retain Your Personal Data only for as long as necessary for the purposes outlined in this Online Privacy Policy. We will retain and use Your Personal Data to comply with legal obligations, resolve disputes, enforce legal agreements and policies, and for internal analysis purposes.

Usage Data is generally retained for a shorter period, except when used to strengthen security, improve functionality, or when legally obligated to retain it for longer periods.

Transfer of Your Personal Data

Your information, including Personal Data, may be processed at the Credit Union's operating offices and other locations where processing parties are located. This may involve transferring information to computers outside your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those in your jurisdiction.

Your consent to this Online Privacy Policy and submission of information represent your agreement to such transfers. The Credit Union will take reasonable steps to ensure data security and compliance with this Online Privacy Policy during transfers.

Delete Your Personal Data

You have the right to delete or request assistance in deleting the Personal Data collected about you. Our Service may allow you to delete certain information from within the Service. You may also update, amend, or delete your information at any time by signing in to your Account, if applicable, and visiting the account settings section. Alternatively, contact us to request access to, correction, or deletion of any personal information provided to us.

Please note that certain information may need to be retained based on legal obligations or lawful bases.

Disclosure of Your Personal Data

Business Transactions

In the event of a merger, acquisition, or asset sale, your Personal Data may be transferred. Notice will be provided before this transfer occurs, and the data will become subject to a different Online Privacy Policy.

Law Enforcement

Under certain circumstances, the Credit Union may disclose Your Personal Data if required by law or in response to valid requests by public authorities, such as a court or government agency.

Other Legal Requirements

The Credit Union may disclose Your Personal Data in good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property