This California Consumer Privacy Act (CCPA) Notice (“Notice”) is provided by Service Federal Credit Union (“Service CU”, “we” or “us”). This Notice explains how we collect, use, and disclose personal information about California residents. The Notice also explains certain rights that California residents have under the California Consumer Privacy Act.
Collection and Disclosure of Personal Information
In the past 12 months, we have collected the following categories of Personal Information about California residents:
- Identifiers, such as name and government-issued identifier (e.g., Social Security Number);
- Personal information, as defined by Cal. Civ. Code § 1798.80, such as contact information or financial information;
- Certain characteristics, such as sex, age, military status, and/or marital status;
- Commercial information, such as transaction information and purchase history;
- Biometric information, such as fingerprints and voiceprints;
- Internet or network activity information, such as browsing history and interactions with our website, applications, and emails;
- Geolocation data, such as device location and Internet Protocol (IP) location;
- Audio, electronic, visual, and similar information, such as call and video recordings;
- Professional and employment-related information, such as work history and prior employer;
- Education information; and
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
We collected such Personal Information from the following sources:
- Directly from California residents or their representatives;
- Third party companies or organizations from whom we collect personal data as part of providing products and services, completing transactions, and supporting our everyday operations and business development;
- Third party companies or organizations that provide data to support activities such as fraud prevention, underwriting, collections, and marketing (like credit bureaus or address tracing companies);
- Public records or widely available sources, including social and news media or federal, state, or local government sources;
- Consumer data resellers;
- Service Federal Credit Union Affiliates (for example Service Insure);
- Indirectly from California Residents, for example regarding activity on our website and mobile app or through social media; and
- Third party companies or organizations from whom we collect Personal Information to support human resource and workforce management activities
We have disclosed some of the above categories of Personal Information for business purposes to the following third parties:
- Vendors and service providers that provide services to Service Federal Credit Union as part of providing products and services, completing transactions, and supporting everyday operations, such as website hosting, data analysis, payment processing, information technology and related infrastructure, fraud prevention and data security, customer service, and marketing activities;
- Third party companies or organizations in connection with routine or required reporting, including consumer reporting agencies;
- Our affiliates and subsidiaries, including Service Insure;
- Individuals or organizations that represent California residents, such as a power of attorney, guardian, or legal counsel;
- Other third parties authorized by our members to access their personal information, such as data aggregators, and those authorized to conduct transactions online and via mobile devices, and to support loan fulfillment services; and
- Government agencies, including law enforcement, to support regulatory and legal requirements.
Use of Personal Information
In the past 12 months, we have used Personal Information relating to California residents for one or more of the following business purposes:
- Performing services and offering products, including maintaining or servicing accounts, processing applications, providing member service, verifying your identity, and processing transactions;
- Engaging in advertising or marketing activities;
- Preventing, detecting, and responding to fraud or other security incidents;
- Undertaking activities, including internal research and analysis, to derive consumer insights and to maintain or enhance the quality of our products and services, including our website;
- Maintaining the integrity and the functionality of our information technology systems;
- Responding to legal requests for information, such as subpoenas, warrants, and court orders; and
- And complying with other legal requirements, such as maintaining information for required retention periods.
Sale of Personal Information
California Residents have the right to opt-out of the sale of their Personal Information by a business. It is Service CU’s policy not to sell Personal Information, and we have not done so in the past 12 months. Because Service CU does not sell your Personal Information, we do not offer an opt-out under the CCPA.
Rights Under the CCPA
If you are a California resident, you have the right to:
- Request that we disclose to you the following information covering the 12 months preceding your request (“request to know”):
- the categories of Personal Information that we collected about you and the categories of sources from which we collected such Information;
- the business or commercial purpose for collecting Personal Information about you;
- the categories of Personal Information about you that we disclosed to third parties for a business purpose and the categories of third parties to whom we disclosed such Personal Information; and
- the specific pieces of Personal Information we collected about you.
- Request that we delete Personal Information that we collected from you, subject to applicable exceptions (“request to delete”). As stated above, we do not sell your Personal Information.
- Be free from unlawful discrimination for exercising your rights under the CCPA.
You also have the right to use an authorized agent to make a request under the CCPA on your behalf. Your agent will need to submit documentation, such as written permission or a valid California Power of Attorney, along with their request proving the legal authority of the authorized agent making the request on their behalf. We may deny the agent’s request if the agent does not submit proof that they have been authorized by you to act on your behalf.
Parents/legal guardians making requests on behalf of their minor children will need to include a description of their relationship to the minor child and include a certified copy of the birth certificate or legal documentation to provide proof of their status.
How to Make Requests
If you are a California resident (or an authorized agent thereof), you may make a request for the disclosures described above or make a request to delete Personal Information we collected from you using one of the below methods.
- Using our online portal, you may submit a secure request electronically.
- Calling us toll-free at 1-800-936-7730 to initiate your request.
- Mailing a written request to the following address. Your written request must include your name, the last 4 digits of your account number or SSN/TIN, address, relationship to Service CU (member, non-member, applicant, etc.), the nature of your request, your address, and a phone number where you can be reached.
ATTN: Compliance Dept.
Service Federal Credit Union
3003 Lafayette Rd
Portsmouth, NH 03801
Upon submission of your request, we will take steps to verify your identity or, if applicable, the authorized agent. This may be accomplished by asking you to verify details about your account and information we have on file or by reviewing your signature. Those steps may vary, however, depending on your relationship with Service Federal Credit Union and the intake method.
Further, in rare cases we may require you to visit a Service Federal Credit Union branch or acknowledge your identity before a notary public.
We will work to process all verified requests within 45 days. If we need an extension in order to process your request, we will reach out to you.
Privacy and data protection laws, other than the CCPA, apply to much of the Personal Information that we collect, use, and disclose. When these laws apply, Personal Information may be exempt from, or outside the scope of, Requests to Know and Deletion Requests. As a result, in some instances, we may decline all or part of a Request to Know or Deletion Request related to this Personal Information. This means that we may not provide some or all of this Personal Information when you make a Request to Know. Also, we may not delete some or all of this Personal Information when you make a Deletion Request.
In some instances, we may not be able to honor your request; for example, we will not honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we may not honor your request where an exception applies, such as where we are required to maintain the information to comply with state or federal law or where the Personal Information that we maintain about you is not subject to the CCPA’s rights.
We will advise you in our response if we are not able to honor your request. We will not provide Social Security Numbers, driver’s license numbers or government-issued identification numbers, financial account numbers, healthcare or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.
Contact for More Information
For any questions or concerns regarding the CCPA or Service Federal Credit Union’s CCPA request process, please call us at 800-936-7730 or send an email to our Assistant Vice President of Compliance, Stephanie Kinnett at email@example.com.
Changes to This Notice
We may change or update this Notice in the future. When we do, we will post the revised CCPA Disclosure on this website. This CCPA Disclosure was last updated and became effective on the following date: August 21, 2020.