Privacy PolicyUpdated 04/24 Naheola Credit Union’s App (the “App”) helps you manage your money, view your transactions and accounts, making it easy to manage your finances on the go. The app provides the Services to users on behalf of their financial institution (“Your Financial Institution”) as a service provider. This Privacy Notice, in combination with relevant privacy notices that Your Financial Institution provides to you (e.g., pursuant to financial privacy laws), informs you of the policies and practices regarding the collection, use and disclosure of any personal information that the app collects from or about users in connection with our mobile application (the “Services”). The specific capabilities of the Services available to you vary depending on Your Financial Institution. You can find more information about Your Financial Institution’s privacy policies and your choices at your Financial Institution’s website or by contacting Your Financial Institution. Depending on the services offered by Your Financial Institution the app may allow you to:
THE TYPES OF INFORMATION THE APP COLLECTS The app may collect personal information from you in the following ways: (a) Personal Information You or Your Financial Institution Provide to us.
(b) Personal Information Collected from Third Parties. We may collect certain information from identity verification services and consumer reporting agencies, including credit bureaus, in order to provide some of our Services. (c) Personal Information Collected Via Technology. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as:
HOW THE APP USES YOUR INFORMATION (a) General Use. In general, the app uses your personal information to respond to your requests as submitted through the Services, to provide you the Services you request, and to help serve you better. The app uses your personal information in the following ways:
(b) Compliance and protection. We may use your personal information to:
(d) Creation of Non-Identifiable Data. The app may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties in its discretion. DISCLOSURE OF YOUR PERSONAL INFORMATION We disclose your personal information as described below. (a) At the Direction of Your Financial Institution. We may share your information with Your Financial Institution or with third parties at the direction of Your Financial Institution. Other than as described in this Privacy Notice in connection with the Services, this Privacy Notice does not apply to the processing of your information by Your Financial Institution or third parties with whom we share information at Your Financial Institution’s direction. (b) Third Party Service Providers. We may share your personal information with third party or affiliated service providers that perform services for or on behalf of us, for the purposes described in this Privacy Notice, including: to provide you with the Services; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the Services; to provide technical support; and/or to provide other services to the App. (c) Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If our company, business or assets is acquired by another company, that company will possess the personal information collected by us and the company will assume the rights and obligations regarding your personal information as described in this Privacy Notice. LINKS TO OTHER SITES The Services may contain links to third party websites. When you click on a link to any other website or location, you will leave the Services and go to another site and another entity may collect personal and/or anonymous information from you. The app’s provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, does not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Notice do not apply to these outside websites. We encourage you to read the privacy notice of every website you visit. YOUR CHOICES REGARDING YOUR INFORMATION You have several choices regarding use of information on the Services. (a) How We Respond to Do Not Track Signals. Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communications. There is currently no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise its policy on responding to these signals. (b) Access, Update, or Correct Your Information. You can access, update or correct your information by changing preferences in your account. To do so, you should contact Your Financial Institution. For additional requests, please contact Your Financial Institution on whose behalf we are providing the Services to you. (c) Opting Out of Email or SMS Communications. If you have signed-up to receive our email marketing communications, you can unsubscribe any time by clicking the "unsubscribe" link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information under "Contact Us" below. If you provide your phone number through the Services, we may send you notifications by SMS, such as provide a fraud alert. You may opt out of SMS communications by unlinking your mobile phone number through the Services. (d) Opting Out of Location Tracking. If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the Services. SAFEGUARDS AND RETENTION We implement reasonable administrative, technical and physical measures in an effort to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information. A NOTE ABOUT CHILDREN The Services are not directed towards individuals under the age of 18, and we do not intentionally gather personal information about visitors who are under the age of 18. If a child under 18 submits personal information to us and we learn that the personal information is the information of a child under 18, we will attempt to delete the information as soon as possible. PRIVACY NOTICE UPDATES This Privacy Notice is subject to occasional revision. Your Financial Institution may notify you, in their sole discretion, of any material changes in its collection, use, or disclosure of your personal information by posting a notice on the Services. Any material changes to this Privacy Notice will be effective thirty (30) calendar days following notice of the changes on the Services or immediately where no notice is given. These changes will be effective immediately for new users of the Services. If you object to any such changes, you must notify us prior to the effective date of such changes that you wish to deactivate your account. Continued use of the Services following notice of any such changes (or use of the Services after any such changes) shall indicate your acknowledgement of such changes. Google Analytics Many websites and apps use Google services to improve their content. When they integrate Google services, these sites and apps share information with Google. We use Google Analytics to better understand how users are visiting and using our sites. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. Google Analytics collects the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. You may review further information about how Google Analytics collects and processes data and how to control the information sent to Google at “How Google uses information from sites or apps that use our services” at google.com/policies/privacy/partners/ CONTACT US If you have any questions or complaints about this Privacy Notice or The App’s data collection or processing practices, or if you want to report any security violations to us, please contact us by email at: support@naheola.com or by mail at: Naheola Credit Union |
