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Privacy Policy
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Privacy Policy
Effective Date: March 29, 2024.
Last Updated: March 28, 2024.Citizens Equity First Credit Union and its wholly-owned subsidiary, CEFCU Financial Services®, Inc., (collectively for purposes of this Privacy Policy, "CEFCU", "us," or "we") is/are committed to protecting the privacy of certain data we collect when you access this website and mobile apps or other online media under our operation and control (collectively, the "Site").
This Privacy Policy ("Policy") describes our policies and practices regarding our collection, use and disclosure of information you submit or we obtain in connection with your use of our Site. This Policy is incorporated into and subject to the Website Terms of Use. Please see our Gramm-Leach-Bliley Act ("GLBA") Privacy Notice for additional information.
Read this Policy carefully before using the Site or submitting personal information to us. BY ACCESSING OR USING THE SITE YOU CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS SET FORTH IN THIS PRIVACY POLICY.
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Changes to this Policy. We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated Policy on our website and update the effective date. Your continued use of our website or any product or service we provide following the posting of changes constitutes your acceptance of such changes.
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Information We Collect. We may collect personal information that you provide directly to us, such as information you submit when you visit the Site. We may also collect information that is passively or automatically collected from you, such as information collected from your browser or device. We use this information to operate the Site, carry out our business, comply with laws and for other purposes described herein.
When you contact us, schedule an appointment, or interact with our chatbot we may collect information including the following:
- Name
- Address
- Email address
- Phone number
Please note that when you interact with our chatbot, your chat may be recorded or transcribed and may be monitored or reviewed by others for training, quality control, or other purposes.
When you apply for a position with us, we collect
- Name and contact information
- Email address
- Password
- Content of your application or CV
If you open an account with us, apply for a loan or insurance, perform online banking, use your credit or debit card, or pay insurance premiums we collect
- Name and contact information
- Social Security number or individual taxpayer identification number
You do not have to provide the above information to access or use other sections of the Site; however, if you do not provide certain requested information, we may not be able to provide you with some of the content, information, or services we offer.
As you navigate through the Site, information is also collected automatically to help us gather information about our visitors' browsing activities in order to improve our website and better serve our members/consumers. Some of this data may be aggregated. We use this data to analyze trends, track visitor movement, and gather demographic information. This information may include:
- IP Address
- Country; Time zone setting
- OS, platform, browser type and version
- Information about your computer and internet connection
- Usage details including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website
- Search terms
Statistical Data. To monitor utilization of the Site and continuously improve its quality, we may compile statistical information concerning the usage of the Site using analytics services, such as those provided by Google Analytics. Examples of this information would include: the number of visitors to the Site, or to sections or pages within the Site, patterns of traffic flowing through the Site, length of time spent on the Site, or in sections or pages of the Site, the other sites that refer visitors to the Site, the pages of the Site that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Site. The analytics services may transfer this information to third parties in case of a legal obligation or if a third-party processes data on behalf of that service.
To compile this information, we may collect and store:
- Your IP address
- Your operating system version
- Your browser version
- The pages you visit within the Site
- The length of time you spend on pages within the Site
- The site from which you linked to ours
- Search terms you used in search engines which resulted in you linking to the Site, etc.
We provide calculators and other online tools to assist visitors in making financial decisions. These tools do not collect or store any information entered by web visitors. Applications for services, accounts, or loans you submit through Online Banking, Open an Account, and/or Apply for a Loan and forms that you complete and submit on our website are protected in accord with this Policy.
When you log in to Online Banking, Open an Account, and/or Apply for a Loan, your identity is no longer anonymous; each username corresponds to a specific member/consumer and that information is collected and retained. To ensure the security of your accounts and information, all actions are monitored and tracked. You should never share your username and/or password with another person to ensure the security and privacy of your accounts and information. Refer to the Online Banking, Open an Account, and/or Apply for a Loan disclosures for complete privacy, security, and usage information.
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Cookies and Similar Technology. We may use technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons to recognize you when you return to the Site, to provide services, and help improve the quality of our service when you visit our Site. We also use cookies to tailor our products, services and advertising to suit your personal interests, estimate our audience size, track visits our Site, to process your requests, and, as applicable serve you targeted ads.
A cookie is a small file consisting of letters and numbers that automatically collects certain information from you. This file uniquely identifies and recognizes your browser or device and transmits information back to the server. Depending on the cookie type, it may perform different functions such as remembering your preferences, improving the quality of your visit, recording the website pages you view, and remembering the name or address you entered during a visit. We use cookies to tailor our products and services, estimate our audience size, track visits to our Site and process your requests. Our Site uses essential, functional, and performance cookies to function and perform as designed and analytics cookies to understand how you use the Site, improve its functionality, and other related purposes.
The Site may also use:
- Web beacons. These small electronic files, also known as pixels, are set by us or third parties, help with functions such as tracking, analytics, counting Site visitors or for related marketing and media services. These pixels may collect your email, name, order items and ID, page ID, quantity, unit price, size, and product ID. This data is anonymized.
- Facebook meta pixel. This pixel is used for tracking and may be used for serving targeted ads. It tracks information such as your page view, view content, search, add to cart or Wishlist, purchase information, sign up, download, submit form, or user information (IP address, browser information). This data is anonymized.
- URL trackers. These third party trackers are strings of code that track user behavior after clicking on a URL for marketing purposes. This data is anonymized.
- Chatbot. The Site uses a chatbot to process and respond to user questions. The chatbot is an automated bot. The user's interaction with the chatbot may be recorded and aggregated for customer relations management history.
- Session replay. We record your interaction with the Site to help us analyze and understand how the Site is utilized by visitors and to help improve it. This tool may record information such as your clicks, scrolls and mouse movements, feedback polls, country, duration, device, name, email, ID, browser, OS, and IP address. Some of this data is anonymized.
Controlling cookies. You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. Most browsers will allow you to block or refuse cookies. However, you may need to manually adjust your preferences each time you visit a 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 Site. For more information, see the Help section of your browser. Please note that if you block certain cookies, some of the services and functionalities of our Site may not work properly including online account services such as Online Banking.
Embedded Content. The Site contains embedded content (e.g., videos). Embedded content may place third party cookies on your device that track your online activity to enhance your experience or assess the success of their application. We have no direct control over the information these cookies collect, and you should refer to their website privacy policy for additional information.
Social Media Plugins. This Site uses social media plugins (e.g., Facebook, Twitter, Instagram, YouTube) to enable you to easily share information with others. When you visit our Site, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our Site. If you are logged into the social media website while browsing our Site, the social plugins allow that social media website to share data about your activities on our Site with other users of their social media website. For example, Facebook Social Plugins allow Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends' Facebook activity on our website. We do not control any of the content from the social media plugins. For more information about social plugins from other media websites you should refer to their privacy and data/information sharing statements/policies.
IMPORTANT: By using the Site, you consent to the processing of any personal information for the analytics purposes and functions described above.
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Do Not Track. "Do Not Track" is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. We do not track Site users over time and across third party websites. Since the Site is not configured to detect Do Not Track signals from a user's computer, we are unable to respond to Do Not Track requests.
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How We Use Your Personal Information. In general, we will use the personal information we collect only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, and as otherwise provided in this Policy. For example, we may use your personal information in the following ways:
- To manage and present our Site and its contents to you including enabling your access.
- To provide certain products, services and information you request.
- To provide customer service.
- To respond to your inquiries, including to investigate and address your concerns.
- To communicate with you including providing notices and information about the Site and related services.
- To create and administer your account(s).
- To verify your identity.
- To track your location so we can direct you to our nearest Member Center or ATM.
- To allow you to participate in interactive features on our Site.
- For our marketing and advertising purposes or joint marketing activities.
- To share information about your transactions, experiences, credit worthiness or insurability with affiliates for their everyday business purposes.
- To share information with affiliates or non-affiliates for their marketing purposes unless you have opted out.
- For our research and development efforts.
- For other everyday business purposes such as product development, processing transactions, contract management, IT and website administration and improvement, training, quality control, fulfillment, analytics, security, fraud prevention including investigations, corporate governance, and reporting.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To ensure your information is accurate and to personalize our products and services.
- For the recruiting and application process or managing the employment relationship.
- To fulfill any other purpose for which you provide it.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
- To comply with legal or regulatory obligations; respond to court orders and law enforcement requests; investigate, establish or defend allegations or legal claims.
- For public safety purposes.
- To report to credit bureaus.
- As permitted or required by law.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
For additional information on how we use your nonpublic personal information, please see our GLBA Privacy Notice.
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Disclosing Your Information. To carry out the purposes outlined above, we may disclose your personal information to your agent or representative, our subsidiaries, affiliates or business partners, non-affiliates, service providers and contractors (e.g., analytics services, background check vendors, payroll processors, marketing services, and information technology vendors), professional services providers (e.g., accountants and attorneys), and government entities.
We may also disclose your personal information to third parties, as necessary, to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.
Lastly, we may transfer personal information to a third party as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of or acquires all or part of the assets of our business.
In general, we will not disclose your personal information except with your consent and as described in this Policy and our GLBA Privacy Notice.
We may disclose aggregated information about our users and information that does not identify any individual.
In no case will we sell or license your data to third parties, except as required or permitted by law, as set forth above, or as disclosed in our GLBA Privacy Notice.
For information on how we share or disclose your nonpublic personal information, please see our GLBA Privacy Notice.
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Safeguarding of Information. We understand the confidential and secure nature of your personal and financial data and have multiple security measures in place to safeguard the security of information obtained through the Site. For example, we have implemented a security program that contains administrative, technical and physical controls that are designed to reasonably safeguard your data from unlawful use, unauthorized access or disclosure.
Applications for services, account(s) or loan(s) that you submit through Online Banking, Open an Account, or Apply for a Loan and forms that you complete and submit on our website are submitted through secure, encrypted web pages. You can verify the security of a web page by looking for the "locked padlock" icon which most browsers display as a sign of a secure web page. To ensure the encryption of your web visit, you should ensure that you are using the most current web browser available. When you have logged in to Online Banking, Open an Account, or Apply for a Loan, all transactions and information are secure. We utilize the latest in technology to monitor Online Banking, Open an Account, and Apply for a Loan activity to protect your transactions and information. Built-in security measures include a session time-out (your Online Banking, Open an Account, or Apply for a Loan session will automatically log out after a period of inactivity), log in error lockout (after repeated incorrect log in attempts), and multi-factor authentication to verify your identity before you can log in.
We conduct frequent and regular backups of your information and utilize redundant information practices to protect your information from being lost, altered, or corrupted due to unforeseen equipment malfunctions. As a result, cefcu.com, Online Banking, Open an Account, and/or Apply for a Loan may be unavailable due to system maintenance or circumstances beyond our control.
Even though we have taken steps to protect your personal information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal information. No system for safeguarding personal or other information is 100% secure and there is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, physical, or technical safeguards.
You should never share your username and/or password with another person to ensure the security and privacy of your accounts and information. Please refer to the Online Banking, Open an Account, and/or Apply for a Loan disclosures for complete privacy, security, and usage information.
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How Long We Retain Your Information. We retain your personal information for as long as necessary, including to provide you products and services, while you have an open account with us, or as required by applicable law or regulation. We may retain your personal information for longer if it is necessary to comply with our legal or reporting obligations, resolve disputes, to exercise or defend against a legal claim, etc.
We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you.
To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; and applicable legal requirements.
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Links to Third Parties' Sites and Third-Party Integrations. We are committed to providing you with the most complete information possible to help you make sound financial decisions. As a convenience to you, we may link from our website to other websites or Internet resources operated by third parties. When you link from our website to a third-party website, the linked website will appear in a new browser window or an alert will appear to notify you that you are leaving our website. Links to third-party websites are solely for informational purposes and should not be construed as our endorsement or guarantee of the information or services provided on the linked website. We do not control third-party websites and are not responsible for the content on linked websites. Third-party website privacy, security, and other policies may differ from this Policy. Please review a linked website's policies before providing personal information on that website.
We may also provide links to third party integrations. Third party integrations are websites or platforms that synchronize with our Site to provide you with additional functionality, tools, or services such as maps, sending requested information, etc. You acknowledge and agree we are not responsible for the availability of third-party sites, resources, or integrations and do not endorse and are not responsible or liable for any content, advertising, goods, services or other materials on, available through, or provided by such sites, resources, or integrations. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of personal information that you provide, or is collected by, such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites.
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Information of Children. The Site is not directed to children as the products and services on this Site are intended for persons 13 years of age and older. We do not have actual knowledge that we sell or share personal information of persons under 16 years of age.
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Applicable law. This Policy is governed by the internal substantive laws of Illinois, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the state and federal courts within Illinois. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.
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Mobile Apps. We provide mobile apps that can be downloaded to your smartphone or mobile device. In addition to providing the ability to use or request our products and services, our apps may collect personal and other information that will be used or disclosed in accordance with this Policy. Please see our CEFCU's Privacy Policy for CEFCU Mobile Banking Application for additional information.
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Your Choices Regarding Your Personal Information. You can always limit the information you provide to us, but if you choose not to provide certain requested information, you may be unable to access some of the services and content on the Site. You can also limit the communications that we may send you by following a simple opt-out process. Simply follow the instructions in our advertisement/promotional emails to opt-out of receiving future marketing communications.
CALIFORNIA RESIDENTS
(View complete CEFCU Privacy Policy)
"Shine the Light Law". If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of CEFCU to third parties for the third parties' direct marketing purposes. Requests may be made one time per calendar year. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2023 will receive information regarding 2022 sharing activities). To make such a request, write us at: Citizens Equity First Credit Union, Compliance Department, P.O. Box 1715, Peoria, IL 61656-9989.
"California Consumer Privacy Act" ("CCPA") Section. The following California Privacy Policy provisions ("CCPA Section") apply solely to individuals who are residents of the State of California (hereinafter, "consumers" or "you"). This CCPA Section describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about you, including personal information we obtain when you access or use the Site, or through other channels including but not limited to phone and email conversations, social media interactions on our websites, viewing our emails, visiting one of our locations, or through our authorized services providers.
This CCPA Section supplements and amends the information contained in the Policy with respect to California residents. Any terms defined within the CCPA have the same meaning when utilized within this CCPA Section. The other provisions of the Policy continue to apply except as modified in this CCPA Section.
Please read this CCPA Section carefully before using the Site or otherwise submitting information to us. By visiting the Site or otherwise submitting information, you indicate your understanding that the collection, use, and disclosure of your information is subject to the terms of this CCPA Section and our Website Terms of Use. Except as otherwise noted, any capitalized terms not defined in the CCPA Section have the meaning set forth in the Policy.
IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS DESCRIBED IN THIS CCPA SECTION, PLEASE DO NOT PROVIDE US WITH SUCH INFORMATION.
This CCPA Section does not apply to "nonpublic personal information" subject to the Gramm-Leach-Bliley Act ("GLBA"). Nonpublic personal information generally means any information that is not publicly available and that a consumer, as defined by GLBA, provides to a financial institution to obtain a financial product or service from the institution; results from a transaction between the consumer and the institution involving a financial product or service; or, a financial institution otherwise obtains about a consumer in connection with providing a financial product or service. For information on our privacy practices regarding nonpublic personal information, please see our GLBA Privacy Notice.
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Personal Information We Collect
As described below, we may collect or have collected in the preceding 12 months the following categories of personal information ("PI" or "personal information"). We may add to the categories of PI we collect and the purpose we use PI. In that case, we will inform you by posting an updated version of this CCPA Section on the Site.
- Identifiers. Examples include real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
- Personal information described in subdivision (e) of California Civil Code Section 1798.80. Examples include name, characteristics or description, address, telephone number, account number, credit card number.
- Characteristics of protected classifications under California or federal law. This category includes characteristics of protected classifications under California or federal law.
- Commercial information. This includes services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information. Examples include browsing history, search history, a consumer's interaction with an internet website, application, or advertisement.
- Geolocation data. This might include location information while using one of our apps.
- Audio, electronic, visual, thermal, olfactory, or similar information. This category includes, without limitation, information collected from voicemail messages, while speaking with one of our service representatives, and/or by video camera.
- Professional or employment-related information. This category includes, without limitation, information regarding your employer and title, job applications, and information related to managing the employment relationship.
- Education information. This category includes, without limitation, information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
- Sensitive personal information. This category includes personal information that reveals a consumer's social security, driver's license, state identification card, or passport number; personal information that reveals 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; personal information that reveals a consumer's precise geolocation; personal information that reveals a consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership; personal information that reveals the contents of a consumer's mail, email, and text messages unless we are the intended recipient of the communication; personal information that reveals a consumer's genetic data; 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 data related to citizenship or immigration status.
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
- Publicly available information.
- Lawfully obtained, truthful information that is a matter of public concern.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA's scope, such as certain health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act (GLBA), or the California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
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Categories of Sources from Which Personal Information Is Collected.
- You. We may collect your personal information when you contact or communicate with us, interact with our chatbot or website or mobile application, input information on forms provided by us on our website, submit applications and forms provided by us, submit an application for employment, or during the employment relationship.
- News outlets.
- Social media and related services. We may collect information about you through your social media services consistent with your settings on those services.
- Third Parties. We may collect information about you from third-party sources that are lawfully entitled to share your data with us including your representative or authorized agent, financial companies, our affiliates, credit bureaus, and service providers that collect information on our behalf.
- Information Collected Indirectly or Automatically. As you navigate through and interact with our Site, we may compile statistical information concerning your usage of the Site. To do so, we may collect certain information about your equipment, IP address or browsing actions and patterns. We may also collect your mobile device's GPS signal.
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Business or Commercial Purposes for Which We Collect Your Personal Information. See sections 5 and 6, above.
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Disclosing Personal Information. In general, we will not disclose your personal information except with your consent and as described in this Policy and our GLBA Privacy Notice. We may disclose your personal information for the same reasons that we may use it, as described in this Policy, which includes disclosing it to our affiliates and non-affiliates, as we deem necessary to carry out those purposes. We endeavor to choose affiliates and non-affiliates whose standards for the protection of data match ours. The following chart describes the categories of personal information we have collected or may collect about you and, for each category, identifies the categories of third parties to whom we may or have disclosed that information in the preceding 12 months. Please also see section 6, above.
Categories of Personal Information Categories of Third Parties to Whom Disclosed Identifiers and personal information described in subdivision (e) of California Civil Code Section 1798.80 Third parties as directed by you.
Your union.
Other financial companies.
Our affiliates, business partners, and non-affiliates. For example, we might disclose your personal information for purposes of collaborating on services or marketing.
Service providers. For example, we may disclose information to service providers that assist with analyzing data, marketing and advertising, information technology services, payroll processing, background checks, benefits administration, and data storage. We might also authorize our service providers to collect personal information on our behalf.
Third parties as necessary to comply with federal, state, or local laws; comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; to cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; to detect, investigate and prevent fraud or other unlawful activities; to protect and defend ourselves, our property, our employees, our customers, and our users; and to exercise or defend legal claims.
Professional services providers such as attorneys and accountants.
Governmental entities.
Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Characteristics of protected classifications under California or federal law Third parties as directed by you.
Affiliates.
Our business partners. For example, we might disclose personal information of employees to one of our business partners for payroll, employment, benefits, or leave purposes.
Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf.
Professional services providers such as attorneys and accountants.
Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Governmental entities.
Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies or other similar identifiers Third parties as directed by you.
Other financial companies.
Our affiliates, business partners, and non-affiliates. For example, we might disclose your personal information for purposes of collaborating on services or marketing.
Service providers. For example, we may disclose information to service providers that assist with analyzing data, marketing and advertising, information technology services, payroll processing, background checks, benefits administration, and data storage. We might also authorize our service providers to collect personal information on our behalf.
Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Professional services providers such as attorneys and accountants.
Governmental entities
Internet or other electronic network activity information Third parties as directed by you.
Affiliates.
Our business partners. For example, we might disclose personal information of employees to one of our business partners for payroll, employment, benefits, or leave purposes.
Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf.
Professional services providers such as attorneys and accountants.
Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Governmental entities.
Marketing partners.
Geolocation data Third parties as directed by you.
Affiliates.
Our business partners. For example, we might disclose personal information of employees to one of our business partners for payroll, employment, benefits, or leave purposes.
Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf.
Professional services providers such as attorneys and accountants.
Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Governmental entities.
Audio, electronic, visual, thermal, olfactory, or similar information. Third parties as directed by you.
Affiliates.
Our business partners. For example, we might disclose personal information of employees to one of our business partners for payroll, employment, benefits, or leave purposes.
Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf.
Professional services providers such as attorneys and accountants.
Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Governmental entities.
Professional or employment-related information. Other financial companies.
Our affiliates, business partners, and non-affiliates. For example, we might disclose your personal information for purposes of collaborating on services or marketing.
Service providers. For example, we may disclose information to service providers that assist with analyzing data, marketing and advertising, information technology services, payroll processing, background checks, benefits administration, and data storage. We might also authorize our service providers to collect personal information on our behalf.
Professional services providers such as attorneys and accountants.
Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Governmental entities.
Education Information Third parties as directed by you.
Affiliates.
Our business partners. For example, we might disclose personal information of employees to one of our business partners for payroll, employment, benefits, or leave purposes.
Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf.
Professional services providers such as attorneys and accountants.
Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Governmental entities.
Sensitive personal information Third parties as directed by you.
Affiliates.
Our business partners. For example, we might disclose personal information of employees to one of our business partners for payroll, employment, benefits, or leave purposes.
Third parties that perform services on our behalf. For example, we may disclose information to certain service providers, information technology providers, payroll and benefits managers, and data storage companies. We might also authorize our service providers to collect personal information on our behalf.
Professional services providers such as attorneys and accountants.
Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.
Governmental entities.
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Selling or Sharing Personal Information.
- We do not sell or share your PI as those terms are defined in the CCPA.
- We do not have actual knowledge that we have sold or shared personal information of minors under age 16.
- Because we do not sell or share your PI as those terms are defined in the CCPA, we do not process opt-out preference signals.
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Sensitive Personal Information. We do not use or disclose your sensitive personal information for purposes other than those specified in Section 7027(m) of the California Consumer Privacy Act Regulations. We may only disclose your sensitive personal information as follows:
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or 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 us 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 a consumer's current interaction with us, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with us.
- To perform services on our behalf.
- To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by us.
- To collect or process sensitive personal information where the collection or processing is not for the purpose of inferring characteristics about a consumer.
- Consumer Rights. The CCPA provides California consumers with the following rights, subject to certain exceptions:
Right to Request Deletion
You have the right to request that we delete your PI from our records, subject to certain exceptions.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers, contractors, and third parties to delete your PI from their records.
CEFCU is not required to comply with your request to delete your PI if it is necessary for CEFCU (or its service provider) to maintain your PI to:
- Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between CEFCU and you.
- Help to ensure security and integrity to the extent the use of the consumer's PI is reasonably necessary and proportionate for those purposes.
- Debug to identify and repair errors that impair existing intended functionality.
- 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.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research that confirms or adheres to all other applicable ethics and privacy laws, when CEFCU's deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if you have provided informed consent.
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with CEFCU and compatible with the context in which the consumer provided the information.
- Comply with a legal obligation.
Right to Know
You have the right to request that we disclose the following to you as it relates to the 12-month period preceding CEFCU's receipt of your verifiable consumer request (see below):
- The categories of PI we have collected about you.
- The categories of sources from which the PI was collected.
- The business or commercial purpose for collecting, selling, or sharing PI.
- The categories of PI we disclosed or sold for a business purpose.
- The categories of third parties we disclosed PI to, by the category of PI.
- The specific pieces of PI we collected about you.
Right to Request Correction
You have the right, subject to certain limitations, to request that we correct any inaccurate personal information we maintain about you. Upon receipt of a verifiable consumer request, and as required by the CCPA, we will take appropriate steps to respond to your request.
Right Not to Receive Discriminatory Treatment
You have the right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of goods or services if you exercise your rights under the CCPA. Employees, applicants, and independent contractors have the right not to be retaliated against for the exercise of their rights conferred by the CCPA.
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Submitting Consumer Rights Requests
To exercise the rights described in this CCPA Section, please submit a verifiable consumer request to us by either calling us at 1-888-556-7376 or by visiting https://www.cefcu.com/forms/contact/ccpa.
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Verifiable Consumer Requests
We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual who is:
- the consumer who is the subject of the request,
- a consumer on behalf of the consumer's minor child, or
- by a natural person or person registered with the California Secretary of State authorized to act on behalf of a consumer.
If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us.
Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use the PI we collect from an individual to determine a verifiable consumer request for any other purpose, except as required by law.
We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will attempt to respond to a verifiable consumer request within forty-five (45) days of receipt, but we may require up to ninety (90) days to respond, under which circumstances we will notify you of the need for an extension.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. With respect to Personal Information collected on and after January 1, 2022, and to the extent expressly permitted by applicable regulation, you may request that such disclosures cover a period beyond the 12 months referenced above, provided doing so would not be impossible or require a disproportionate effort by us. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.
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Authorized Agents
You may authorize a natural person or a business registered with the California Secretary of State to act on your behalf with respect to your rights under this CCPA Section. Unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf, and we may require you to verify your identity directly with us or directly confirm with us that you provided the authorized agent permission to act on your behalf. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.
Contact Us.
If you have any questions regarding this Policy or the privacy of your personal information, please contact us at:
Phone: 1-888-556-7376
Postal Address:
Citizens Equity First Credit Union
Compliance Department
P.O. Box 1715
Peoria, IL 61656-9989 -
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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