Privacy Policy

NOTICE OF YOUR FINANCIAL PRIVACY RIGHTS

We understand the importance of protecting the privacy of our members. As such, we are committed to maintaining the confidentiality of each member's financial records consistent with state and federal laws. The following documents provide details on our policies regarding the use and protection of your financial information and on how you can limit information sharing.

Mobile App Privacy Permissions

Mobile App Privacy Permissions Includes but May Not Be Limited To:

Permissions	Function	Example
CAMERA	Allows access to the device’s camera	Mobile Remote Deposit
LOCATION	Allows access to location	Maps
ACCESS TO EXTERNAL STORAGE	Allows access to files/media on this device	Secure message attachments
CONTACTS	Allows access to contacts on the device	Person to Person Payments Recipient list
AUDIO	Allows access to the device’s microphone	Chat
PHONE STATE*	Allows access to information about the user’s device for device identification	Malware / Anti-Phishing for easy solutions integration
IMAGES	Allow access to stored images on the device	Receipt Capture, Mobile Deposit

*PHONE STATE is included in our Android App code; it is only utilized if Easy Solutions is enabled.

ONLINE PRIVACY

Collecting Information

Any personal information collected directly from visitors to our site is used to fulfill visitor-initiated requests. Information regarding domain names and dates and times of website visits is also collected to track website use, measure site traffic and improve site navigation. This statistical information is not used to identify individual visitors. None of the active or passive information we collect online is shared or sold to third parties for any reason.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include publicly available information from government records, or deidentified or aggregated consumer information.

We retain this information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

The table below describes the categories of personal information we have collected from consumers within the last twelve (12) months, the business purpose for the collection of that information, whether that category of information is sold or shared and for how long that category of information will be retained:

Category of Personal Information Collected	Business Purpose for Collection	Sold or Shared	Retention
Identifiers (A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.)	Providing Member service, maintenance of accounts or processing transactions To prevent or respond to fraudulent or malicious activity Qualifying you for a product or service Verifying your identity and contacting you about your account Providing information to you about our products and services Raffles/sweepstakes for giveaways where we collect a name and contact information for follow-up	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations Raffle/sweepstakes information destroyed within one month of event, with exception of winners or consumers who have asked for additional product information, in which case the information will be retained until no longer needed
California Customer Records personal information (A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.)	Providing Member service, maintenance of accounts or processing transactions To prevent or respond to fraudulent or malicious activity Qualifying you for a product or service Verifying your identity and contacting you about your account Providing information to you about our products and services	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations
Protected classification characteristics under California or federal law (Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Providing Member service, maintenance of accounts or processing transactions Complying with equal opportunity laws Performing analysis or research Enhancing the quality of our services	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations
Commercial information (Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.)	Providing Member service, maintenance of accounts or processing transactions Performing analysis or research Enhancing the quality of our services Verifying advertising impressions Qualifying you for a product or service	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations
Biometric information (Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.)	Providing Member service, maintenance of accounts or processing transactions Disclosed to service providers and contractors (e.g Online and Mobile Banking provider) for the stated business purposes. Maintaining security and verifying your identity	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations
Internet or other similar network activity (Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.)	Providing Member service, maintenance of accounts or processing transactions Performing analysis or research	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations
Geolocation data (Physical location or movements.)	To provide closest ATM/branch information on a map within Mobile Banking or our EagleCU.org website map	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations
Sensory data (Audio, electronic, visual, thermal, olfactory, or similar information.)	Voice mails from callers may be stored on our systems Videos may capture visitors to our branches or ATMs for fraud protection Photos of Members attending local events or Credit Union sponsored activities	Not sold or shared	Voice mails are retained based upon recipient and business need Videos are retained indefinitely to comply with legal obligations Photos may publicly remain on social media indefinitely
Professional or employment-related information (Current or past job history.)	Collected when consumers apply for credit or from contractors or service providers for the purpose of locating a Member for debt collection	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations
Non-public education information (Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.)	Applicants for the Credit Union’s annual scholarship program submit their high school/college transcripts to apply for a scholarship.	Not sold or shared	Applications along with transcripts and supporting documents are kept as long as required to comply with legal obligations.
Inferences drawn from other personal information (Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.)	The Credit Union may purchase data from time to time to append to Member profiles for the purpose of improving communications and Member Service.	Not sold or shared	As needed to provide personalized service for existing Members
Images	Allow access to stored images on the device for purpose of mobile deposit, identificatioin, receipt capture	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations

The table below describes the categories of sensitive personal information we have collected from consumers within the last twelve (12) months, the business purpose for the collection of that information, whether that category of information is sold or shared and for how long that category of information will be retained:

Category of Sensitive Personal Information	Business Purpose for Collection	Sold or Shared	Retention
Government identifiers (social security, driver’s license, state identification card, or passport number)	Providing Member service, maintenance of accounts or processing transactions To prevent or respond to fraudulent or malicious activity Qualifying you for a product or service Verifying your identity and contacting you about your account	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations
Complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password)	Providing Member service, maintenance of accounts or processing transactions To prevent or respond to fraudulent or malicious activity Qualifying you for a product or service Verifying your identity and contacting you about your account	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations
Precise geolocation	Not collected	Not sold or shared	N/A
Racial or ethnic origin	Complying with equal opportunity laws Performing analysis or research Enhancing the quality of our services	Not sold or shared	As needed to manage Member accounts and services and comply with our legal obligations
Religious or philosophical beliefs	Not collected	N/A	N/A
Union membership	Not collected	N/A	N/A
Genetic data	Not collected	N/A	N/A
Mail, email, or text messages contents not directed to us	The Credit Union occasionally receives accidental emails or text messages to our main phone number	Not sold or shared	Most accidental emails, texts, and mail are destroyed upon receipt but it depends upon the email or phone number it may have been sent to as some of our emails may not be monitored by the individual
Unique identifying biometric information	Not collected	N/A	N/A
Health information	Not collected	N/A	N/A
Sex life, or sexual orientation information	Not collected	N/A	N/A

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you or your representatives;
Service Providers, Consumer Data Resellers, Credit Reporting Agencies and other similar persons or entities;
Public Record Sources (Federal, State or Local Government Sources);
Information from our Affiliates;
Website/Mobile App Activity/Social Media;
Information from member directed persons or entities or institutions representing a member/prospect; and
Information from business members about individuals associated with the business member (e.g., an employee or board member).

Cookies

Cookies are bits of information that a website sends to a user's computer. The user's computer may then display the information back to the server on subsequent pages, actions or visits. Internet Banking uses session cookies that expire once the session has ended. The use of cookies within Internet Banking is necessary for security and is required to access the system.

Children's Online Privacy

Occasionally we may collect personally identifiable information from children for the purpose of contest notification, survey feedback and online communication. We do not collect any more information than is reasonably necessary for a child to participate in an activity as a condition of participation. This information is collected directly from the child and may include name, email address, home address, telephone number, hobbies or opinions. Reasonable efforts, such as letters, calls or email confirmations are used to gain parental consent or notification when we communicate to children. Parents may at any time request to review the child's personal information, ask to have it deleted and refuse to allow any further collection or use of the child's information. For such requests, email msupport@eaglecu.org, call (949) 639-7851 or write to: Marketing, Eagle CU, P.O. Box 5196, Lake Forest, CA 92609-8696. We recognize that protecting children's identities and online privacy is important and that responsibility rests with us and with parents. The personally identifiable information we collect will not be shared or sold to third parties for any reason.

Links

Links to other websites found here are provided to assist in locating information. The mere fact that there is a link between this website and another does not constitute a product or program endorsement by Eagle Community Credit Union (Eagle CU) or any of its employees. Eagle CU has no responsibility for content of the websites found at these links, or beyond, and does not attest to the accuracy or propriety of any information located there.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your CCPA Rights), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) or contractor(s) to:

Complete the transaction for which we collected the personal information, provide a financial product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers, contractors and other third parties, if any, to take similar action.

Opting Out / Submitting Right to Delete / Inquires

You may opt out of our online information collection process by contacting us via one the methods provided below.

Email:  msupport@eaglecu.org
Call:     (949) 588-9400 or (800) EAGLE CU (324-5328)
Write:   Eagle Community Credit Union
Write:   P.O. Box 5196
Write:   Lake Forest, CA 92609-8696

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