Mobile Banking Privacy Policy

CEFCU’s Privacy Policy for CEFCU Mobile Banking Application

Last updated on August 18, 2023

CEFCU’s Privacy Policy for CEFCU Mobile Banking Application (“Privacy Policy”) describes Our policies and procedures that apply to the access, collection, use, sharing, and disclosure of Your Personal and Sensitive Information when You use the Service and tells You about Your privacy rights and how the law protects You.

We access, collect, use, share, and disclose Your Personal and Sensitive Information solely to provide and improve the Service. By using the Service, You agree to the access, collection, use, sharing, and disclosure of Your Personal and Sensitive Information in accordance with this Privacy Policy.

This Privacy Policy DOES NOT apply to information that:

• We collect offline or on cefcu.com.
• You provide to or is collected on websites You may access through the Service.
• You provide to or is collected by any third party other than a Service Provider.

These third parties may have their own privacy policies, which we encourage You to read before providing information on or through them.

Application Permissions

In order to provide certain features of the Application, the Application will request Your prior permission to access Your Device as follows:

Permission to Access and Collect Information from Your Device’s:	Purpose for Permission	What Happens If You Don’t Give or You Revoke Your Permission?
Contacts
Read your contacts.	Person to Person payment. Recipient contact information used to facilitate payment transfer.	You won’t be able to select recipient contact information, requiring manual entry of contact information.
Location
Approximate location (network-based).	Maps. Location is used to populate map and to improve and customize Our Service.	Map will default to a location that may not be device location.
Precise location (GPS and network-based).	Maps. Location is used to populate map and to improve and customize Our Service.	Map will default to a location that may not be device location.
Photos/Media/Files
Read the contents of your device storage, including images.	eStatements, Secure Message attachments. Attachments received through download are saved on device.	Device may not be able to confirm available storage to download, save and/or access the attachment and/or document requested.
Modify or delete the contents of your device storage, including images.	eStatements, Secure Message attachments. Attachments received through download are saved on device.	Device may not be able to confirm available storage to download, save and/or access the attachment and/or document requested.
Upload the contents of your device storage, including images.	Secure Message attachments.	Device may not be able to confirm available storage to upload/access the attachment image requested.
Storage
Read the contents of your device storage, including images.	eStatements, Secure Message attachments. Attachments received through download are saved on device.	User may not be able to download and/or save attachment and/or document requested.
Modify or delete the contents of your device storage, including images.	eStatements, Secure Message attachments. Attachments received through download are saved on device.	User may not be able to download and/or save attachment and/or document requested.
Upload the contents of your device storage, including images.	Secure Message attachments.	Device may not be able to confirm available storage to upload/access the attachment image requested.
Camera
Take pictures, (images) and videos	Mobile Check Deposit. Picture taken for Mobile Check Deposit is used/shared to process item.	You won’t be able to take a picture of an item; therefore, you won’t be able to use Mobile Check Deposit to deposit Your check.
Wi-Fi connection information
View Wi-Fi connections	Access internet connection. The Application requires internet connection to update information	If network status is unavailable or Device is offline, the Application will not be able to load/start.
Other	Update application and send/receive information. Account information is sent/received.	If network status is unavailable or Device is offline, the Application will not be able to load/start.
Receive data from Internet	Update application and send/receive information. The Application requires internet connection to update information.	If network status is unavailable or Device is offline, the Application will not be able to load/start.
View network connections	Access internet connection. The Application requires internet connection to update information.	If network status is unavailable or Device is offline, the Application will not be able to load/start.
Full network access	Access internet connection. The Application requires internet connection to update information	If network status is unavailable or Device is offline, the Application will not be able to load/start.
Prevent device from sleeping	Allow user to stay in session. Application has a timeout set – allows	Device status may enter rest mode but Application runs in background and eventually will timeout.

You can enable or disable Your permissions to access and collect information from Your Device at any time, through Your Device’s settings.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• "Account" means a unique account created for You to access the Service or parts of the Service.
• "Application" means the software program provided by CEFCU downloaded by You on any electronic device, named CEFCU Mobile Banking.
• "CEFCU" (referred to as either "CEFCU", "We", "Us" or "Our" in this Privacy Policy) refers to Citizens Equity First Credit Union.
• "Country" refers to the United States.
• "Cookies" are small files that are placed on Your computer, mobile device, or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• "Device" means any device that can access the Service such as a computer, a cell phone, or a digital tablet.
• "Personal and Sensitive Information" is any information that relates to an identified or identifiable individual, including but not limited to personally identifiable information, financial and payment information, authentication information, phonebook, contacts, device location, SMS and call related data, inventory of other apps on the device, microphone, camera, and other sensitive device or usage data.
• "Service" refers to the Application and the Application’s Website.
• "Service Provider" means any natural or legal person who processes data on behalf of CEFCU. It refers to third-party companies or individuals employed by CEFCU to facilitate the Service, to provide the Service on behalf of CEFCU, to perform services related to the Service, or to assist CEFCU in analyzing how the Service is used.
• "Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• "You" means the individual accessing or using the Service, or CEFCU, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal and Sensitive Information

Types of Personal and Sensitive Information We Collect in the Service

Personal and Sensitive Information You Provide to Us

While using the Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

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

Personal and Sensitive Information Collected Via Technology

While using the Service, We may automatically collect certain information that may include, but is not limited to:

• Usage Data.
• Device data, such as the type of Device You use, the Internet Protocol address of Your Device, Your Device’s operating system type and version, the type and version of Internet browser You use, Your unique Device identifiers, Your Device’s manufacturer and model, Your Device’s screen resolution, Your Device’s RAM and disk size, Your Device’s CPU usage, the type of Your Device (e.g., phone, tablet, or computer), Your Device’s language settings, Your Device’s mobile carrier, Your Device’s radio/network information (e.g., WiFi, LTE, 3G), general location information such as city, state, or geographic area, and other diagnostic data.
• Online activity data, such as pages or screens You viewed, how long You spent on a page or screen, the time and date of Your visit, the website You visited before browsing to the Service, navigation paths between pages or screens, information about Your activity on a page or screen, access times, and duration of access.
• Cookies, which are text files that websites store on a visitor’s Device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping You navigate between pages efficiently, remembering Your preferences, enabling functionality, and helping us understand user activity and patterns.
• Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on Your device outside of Your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Location Information. If You have enabled location services on Your phone and agree to the collection of Your location when prompted by the Services, we will collect Your location information when You use the Services; for example, to provide our fraud detection services. If You do not want us to collect this information, You may decline the collection of Your location when prompted or adjust the location services settings on Your device.

Use of Your Personal and Sensitive Information

CEFCU may use Your Personal and Sensitive Information collected through Your use of the Service for the following purposes:

• To provide the financial services You request through the Service.
• To provide and maintain the Service, including to monitor the usage of the Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal and Sensitive Information You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To manage Your requests: To attend and manage Your requests to Us.
• For other purposes: We may use Your Personal and Sensitive Information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Service, products, services, marketing, and Your experience.

Sharing Your Personal and Sensitive Information

We may share Your Personal and Sensitive Information in the following situations:

• With Service Providers: We may share Your Personal and Sensitive Information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.
• For business transfers: We may share or transfer Your Personal and Sensitive Information in connection with, or during negotiations of, any merger, sale of CEFCU assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your Personal and Sensitive Information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your Personal and Sensitive Information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share Your Personal and Sensitive Information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: We may disclose Your Personal and Sensitive Information for any other purpose with Your consent.

Service Providers, Affiliates, and Business Partners Privacy Protection

All third parties, including Service Providers, Affiliates, and business partners, who may have access to Your Personal and Sensitive Information provide the same or equal protection of such information as stated in this Privacy Policy and required by the App Store Review Guidelines.

Retention of Your Personal and Sensitive Information

CEFCU will retain Your Personal and Sensitive Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal and Sensitive Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

CEFCU will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Service, or We are legally obligated to retain this data for longer time periods.

We will delete your Personal and Sensitive Information when We are no longer required to retain that information or, for California residents, if You request We delete that information in accordance with the requirements of and subject to the limitations of CEFCU’s Privacy Policy for California Residents.

Transfer of Your Personal and Sensitive Information

Your information, including Your Personal and Sensitive Information, is processed at CEFCU's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, Country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

CEFCU will take all steps reasonably necessary to ensure that Your Personal and Sensitive Information is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal and Sensitive Information will take place to an organization or a country unless there are adequate controls in place including the security of Your Personal and Sensitive Information.

Disclosure of Your Personal and Sensitive Information

Business Transactions

If CEFCU is involved in a merger, acquisition, or asset sale, Your Personal and Sensitive Information may be transferred. We will provide notice before Your Personal and Sensitive Information is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, CEFCU may be required to disclose Your Personal and Sensitive Information if required to do so by law or in response to a valid summons, subpoena, or order by public authorities (e.g., a court or a government agency).

Other legal requirements

CEFCU may disclose Your Personal and Sensitive Information in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of CEFCU
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of users of the Service or the public
• Protect You or Us against legal liability

Security of Your Personal and Sensitive Information

The security of Your Personal and Sensitive Information is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal and Sensitive Information, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal and Sensitive Information

The Service Providers We use may have access to Your Personal and Sensitive Information. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Email Marketing

We may use Your Personal and Sensitive Information to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

Children's Privacy

The Service is not intended for use by anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal and Sensitive Information, please contact Us. If We become aware that We have collected Personal and Sensitive Information from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your Personal and Sensitive Information and Your Country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

The Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the privacy policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

California Residents Privacy Rights

California residents may have additional personal information rights and choices. If You are a California resident, California law may provide You with additional rights regarding our use of Your personal information. To learn more about Your California privacy rights, review Privacy Policy for California Residents.

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Application 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 dirrera@cefcu.com or write us at: Citizens Equity First Credit Union, Compliance Department, P.O. Box 1715, Peoria, IL 61656-9989.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on the Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If You have any questions about this Privacy Policy, You can contact us at:

Citizens Equity First Credit Union
Compliance Department
P.O. Box 1715
Peoria, IL 61656-9989