California Consumer Privacy Act

1.  Personal Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual consumer or device (“personal information”).

1.1.  Personal information does not include:

• Publicly available information from government records,
• De-identified or aggregated consumer information, and
• Information excluded from the CCPA, such as personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

1.2.  Categories of Personal Information Collected:

In the last 12 months, we collected the following categories of personal information: 

• “Identifiers” such as name, alias, address, unique identifier, internet protocol address, email address, account number, Social Security Number, or government identification number; 
• “Other Personal Information” such as 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, or medical information. Some personal information included in this category may overlap with other categories;
• “Protected Characteristics” under California or federal law for classifications such as 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, or veteran or military status;
• “Commercial Information” such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• “Internet or Network Activity” such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement; 
• “Biometric Information” such as 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, or gait;
• “Geolocation Data” such as physical location or movements;
• “Sensory Data” such as audio, electronic, or visual information; 
• “Professional or Employment Related Information” such as current or past job history or performance evaluations; and
• “Inferences” drawn from other personal information such as profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

1.3.  How We Obtain Your Personal Information:

1.4.  How We Use Your Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

1. Performing services for you, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of us or our service providers.  This includes: a) to fulfill or meet the reason for which the information is provided; b) to provide you with information, products, or services that you request from us; c) to provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you; and
2. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
3. Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standard.
4. Debugging to identify and repair errors that impair existing intended functionality.
5. To improve our website and present its contents to you.
6. For testing, research, analysis and product development.
7. As necessary or appropriate to protect the rights, property or safety of you, us or others.
8. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
9. As described to you when collecting your personal information or as otherwise set forth in the CCPA.
10. For marketing purposes, including with third parties.
11. To comply with our legal or regulatory obligations.
12. Otherwise use the personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

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.

We may disclose your personal information to a service provider or third party for a business or commercial purpose. When we disclose personal information with a service provider, we enter a contract that describes the purpose and requires the service provider to both keep that personal information confidential and not use it for any purpose except performing the contract or as expressly provided under the CCPA. 

• Service providers.
• Third parties:
  • With our lending partners, we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Sensory Data, Professional or Employment Related Information, and Inferences.
  • With credit reporting agencies we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Sensory Data, Professional or Employment Related Information, and Inferences.
  • With advisors such as lawyers, banks, and insurers, we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Biometric Information, Geolocation Data, Sensory Data, Professional or Employment Related Information, and Inferences.
  • With governmental and regulatory agencies, we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Biometric Information, Geolocation Data, Sensory Data, Professional or Employment Related Information, and Inferences.
  • With data analytics providers, we share Identifiers, Other Personal Information, Protected Characteristics, Commercial Information, Internet or Network Activity, Geolocation Data, Sensory Data, Professional or Employment Related Information, and Inferences.

1.6.  Sale of Personal Information:

You have the right to opt-out of the “sale” of your personal information. Under the CCPA, “sale” is defined broadly is not limited to just the payment of money.  We do not directly sell your personal information in the conventional sense (i.e., for money).  Like many companies, we connect you with other companies that offer services you may be interested in.  We may disclose your personal information to third parties that in turn offer you insurance products or services in exchange for monetary or other valuable consideration.  Such sharing can qualify as a “sale” under the CCPA.

With companies that provide insurance services we  share Identifiers and Other Personal Information. 

We do not knowingly “sell” the personal information for California residents under the age of 16.

2.  Your Rights Under the California Consumer Privacy Act of 2018

The CCPA provides consumers (California residents) with specific rights regarding their personal information - the Right to Know, the Right to Delete, the Right to Opt-Out, and the Right to Non-Discrimination. This section describes your CCPA rights and explains how to exercise those rights.

2.1.  Right to Know:

You have the right to request that we disclose certain information to you about our collection, use, disclosure, and “sale” of your personal information over the past 12 months (“Right to Know”).  Once we receive and verify your request, we will disclose to you:

• Categories of Personal Information Collected and Shared
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or “selling” that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we disclosed your personal information for a business purpose, the categories of personal information shared with each category of third party recipients.
  • For each category of third parties, the categories of personal information that were sold.
• Specific Information
  • The specific pieces of personal information we collected about you.

2.2.  Right to Delete:

You have the right to request that we delete any of your personal information that we collected, retained, and used. Once we receive and verify your request, we will delete your personal information (and direct our service providers to do the same) , unless an exception applies.

We may deny your Request to Delete if retaining the personal information is necessary for us or our service providers to:

• •    Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business's ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
  •    Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  •    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 in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses' deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
  •    To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer's relationship with the business.
  •    Comply with a legal obligation.

2.3.  Right to Opt-Out:

You have the right to opt-out of the “sale” of your personal information.  

You can exercise your Right to Opt-Out by either:

• Calling us at: 866-995-FFCU or 626-445-0950
• You may click here

Before we can respond to a Request to Opt-Out submitted by an authorized agent, we need to confirm not only that person or entity’s authority to act on your behalf but also verify the identity of the authorized agent.

If you are authorized to submit a request on behalf of a California resident, please email us at [email protected] and provide the following information:

1. The consumer’s name, email address, and telephone number.
2. To verify your authorization to request on behalf of a California resident, please attach a copy of one or more of the following to your request email:
   • California Secretary of State entity details and a signed authorization (if the agent is a business), 
   • written permission from the California resident (if the agent is an individual), or 
   • a valid power of attorney
3. To verify your identity, please attach copies of the following to your request email:
   • Valid Government Issued ID (not expired) AND
   • a Utility Bill, Bank Statement, or similar documentation to verify your name and address.

2.4.  Right to Non-Discrimination:

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

3.  Submitting a Verified Consumer Request

3.1.  How to Submit a Request

To make a Request to Know or Request to Delete, please contact us by either:

• Calling us at 866-995-FFCU or 626-445-0950
• Visiting us here 

Only 1) you, 2) a person authorized by you to act on your behalf, or 3) an entity registered with the California Secretary of State and authorized by you to act on your behalf, may make a Request to Know or Request to Delete related to your personal information. You may also make a request on behalf of your minor child.

You may only make a Request for Know twice within a 12-month period. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.  Given the sensitivity of your personal information that we collect and retain, we will need to verify your identity with at least 3 separate pieces of information such as name, address, account number, date of birth, last 4 of your Social Security Number, phone number, etc.  
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Before we can respond to a request submitted by an authorized agent, we need to confirm not only that person or entity’s authority to act on behalf of a consumer but also the identity of the authorized agent.  If you are authorized to submit a request on behalf of a California resident, please email us at [email protected] and provide the following information:

1. To verify your authorization to request on behalf of a California resident, please attach a copy of one or more of the following to your request email:
   • California Secretary of State entity details and a signed authorization (if the agent is a business), 
   • written permission from the California resident (if the agent is an individual), or 
   • a valid power of attorney.
2. To verify your identity, please attach copies of the following to your request email:
   • Valid Government Issued ID (not expired) AND
   • a Utility Bill, Bank Statement, or similar documentation to verify your name and address
3. You will also be required to verify the identity of the consumer for whom you are submitting the request.

3.3.  Response Timing and Delivery Method:

We will acknowledge receipt of the request within 10 days business of its receipt.  We will respond to a request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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 request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

4. Do Not Track

Our site does not respond to Do Not Track signals configured in your web browser.

5. Social Media

We encourage you to review your privacy options and settings with the social media platforms and networks you use to understand what choices you have about sharing information from those platforms and networks with us.

6.  Changes to our California Disclosures and Privacy Policy

We reserve the right to amend these CALIFORNIA DISCLOSURES AND PRIVACY POLICY at our discretion and at any time. When we make material changes to these CALIFORNIA DISCLOSURES AND PRIVACY POLICY, we will notify you by a notice on our website homepage.

7.  How to Contact Us

If you have any questions or comments about this policy, the ways in which we collect and use your personal information, your rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

• Privacy Support Phone: (866) 995-FFCU or (626) 445-0950
• Privacy Support email: [email protected]
• Website: www.foothillcu.org
• Postal Address: Foothill Credit Union, Attn: Foothill Privacy, P.O. Box 660130, Arcadia, California 91066-0130