People Driven Credit Union recognizes our customers’ importance on the privacy and security of their personal information. Our goal is to protect your personal information in every way we interact with you, whether on the telephone, in our lobby, at one of our ATMs, or on the Internet.
It is important for you to be informed of the policies, procedures, and security measures we have in place to safeguard your personal and confidential information. With that in mind, we have developed this policy to help you understand the steps we take to protect your personal information when you use our Internet services.
We may utilize the services of third-party providers to assist us in providing online services, such as website hosting, Internet banking, and bill payment services. Third-party providers are also referred to within this policy as “service providers.”
Information Collected on the Internet
Suppose you are just browsing through our website. In that case, we do not request any personally identifiable information, or collect unique identifying information about you unless you voluntarily and knowingly provide us with that information, such as when you send us an email or complete an application online. If you provide us with this information, it is only used internally to further the purpose for which it was provided.
As part of providing online financial products or services, we may obtain information about our members and website visitors from the following sources:
- Information we receive from you on applications, emails, or other forms;
- Information you provide when you choose to customize our website;
- Information about your transactions with this institution and our affiliates;
- Information we receive from a consumer-reporting agency;
- Information that is generated electronically when you visit our website;
- Information that is generated electronically when you use our internet banking services.
Service providers hosting our website and our Internet banking service may collect general information on our website visitors to help us provide you with banking and other financial services online. They contain the following information on our behalf for security and statistical purposes:
- The Internet address (referral site) which brought you to our website;
- The date and time you access our site;
- The name and version of your web browser;
- The Internet service provider you used when you accessed our site;
- Your Internet Protocol (IP) address;
- The pages visited on our website.
Our service providers may use cookies to collect some of the above information. They may also use cookies for security purposes within our internet banking product. Additionally, cookies may be used for customization and personalization of our website.
Additional information about IP addresses and cookies are provided below.
Internet Protocol (IP) Addresses
An IP address is a number automatically assigned to your computer whenever you are on the Internet. Web servers, the computers that “serve up” web pages, automatically identify your computer by its IP address. When collecting information for us, our service provider does not link IP addresses to anything personally identifiable; however, this institution and its service providers may use IP addresses to audit the use of our site. We can and will use IP addresses to identify users when necessary for security purposes.
Website Cookies
A “cookie” is a small text file or text identifier placed on end users’ computers. Cookies are commonly used on websites and do not harm end users’ systems. Preexpired cookies are used in the AXIS Internet Banking Product. The cookies are shared across an entire session, and end users must accept all cookies while accessing their accounts. All private data stored in cookies by the Digital Insight system are encrypted and for internal use only.
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. The Credit Union uses Google Analytics to better understand how users are visiting and using our sites. Google Analytics collects information such as how often users visit the 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. The Credit Union does 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 the Site, the cookie cannot be used by anyone but Google. You may further review information about how Google Analytics collects and processes data and how to control the information sent to Google by reviewing ‘How Google uses information from sites or apps that use our services’: https://policies.google.com/technologies/partner-sites.
Use of Information Collected
- We do not disclose any non-public personal information about our members, former members, or website visitors to anyone except as permitted or required by law.
- To provide online services such as Internet banking and bill payment, we must disclose certain customer account information to our service providers.
- We do not sell any of your personal information.
- We may disclose aggregate (not personally identifiable) member information we collect on our website to service providers, companies, and/or financial institutions that perform marketing and research services on our behalf and with whom we have joint marketing agreements. Our contracts require these service providers, companies, and/or financial institutions to protect the confidentiality of your personal information to the same extent we must do.
Data Retention
People Driven Credit Union retains different categories of information for different lengths of time, based on the purpose of the data and applicable regulatory requirements.
Loan and credit application data. Information submitted through loan applications, including LoansPQ applications, Q-Cash applications, and mortgage applications processed through Member First, is retained for a minimum of 25 months from the date of application, in accordance with the Equal Credit Opportunity Act and Regulation B. Mortgage application data subject to the Home Mortgage Disclosure Act is retained for a minimum of 3 years. Certain mortgage disclosure records subject to the TILA-RESPA Integrated Disclosure rule are retained for a minimum of 5 years. PDCU may retain this data longer than these minimums for audit, examination, and internal recordkeeping purposes.
Signed loan documents. Executed loan agreements and related documents processed through DocuSign are retained according to PDCU’s internal document retention schedule, generally for the life of the loan plus an additional period required for audit and legal purposes.
Website form submissions. Information submitted through general inquiry and contact forms on this website is retained only as long as needed to respond to the inquiry and is deleted on a routine schedule thereafter. Forms that function as a loan inquiry or pre-application are instead retained under the loan and credit application retention period described above. Internal email notifications generated by form submissions are retained only until the underlying submission has been processed and stored in PDCU’s system of record, after which the notification email is deleted.
Call data. PDCU distinguishes between call tracking data and call recordings. Call tracking data collected through CallTrackingMetrics, used to measure which marketing channel generated a call, is retained for up to 24 months. Call recordings and transcripts, which may include account or personal information shared during a call, are retained for a shorter period, and access is limited to authorized personnel for quality assurance and compliance purposes.
Advertising platform data. Data shared with or generated through Google Ads and Meta advertising is retained for up to 24 months and used for campaign performance and attribution. PDCU does not use member data to build custom or lookalike audiences in a manner that would result in advertising being shown or withheld based on a protected characteristic.
Appointment scheduling data. Information submitted through PDCU’s appointment scheduling system, powered by FMSI, is retained only as long as needed to manage the scheduled appointment and for a limited period afterward for service history purposes.
Employment application data. Information submitted through Paylocity for employment applications is governed separately from this policy, under PDCU’s employment and applicant recordkeeping practices, and is retained for a minimum of 1 year in accordance with federal recordkeeping requirements for job applicants.
Email Policies
We may send you email notices for certain required disclosures if you agree to accept electronic disclosures and/or online account statements. Suppose you have agreed to accept disclosures electronically. In that case, we may send you an email with updates to this policy and/or we may send you an email at least annually to remind you where the Privacy Policy can be viewed from our website.
For more information on how to enroll for electronic disclosures, please contact us at pdcu@peopledrivencu.org. We may also send you emails marketing our products and services. We’ll always give you an opportunity to opt in or opt out of email advertising promotions as required by law.
If you send us an email, please do not include any non-public personal or sensitive information, as email messages may not be secure and/or confidential. We offer secure messaging through our Internet Banking service. You should use the secure messaging service anytime you send us sensitive personal information.
External Third-Party Links
Our website may include numerous links to other third-party sites. These links to external third parties are offered as a courtesy and a convenience to our customers. When you visit these sites, you will leave our website and will be redirected to another site. We do not control linked third-party sites. We are neither an agent for these third parties nor endorse or guarantee their products. We make no representation or warranty regarding the accuracy of the information contained in the linked sites. We suggest you always verify the information obtained from linked websites before acting upon this information. Also, please be aware that these sites’ security and privacy policies may differ from ours, so please read third-party privacy and security policies closely.
While using our website, you may still see our logo when visiting third-party sites. A technique called “Framing” allows us to display our logo and look and feel while allowing you to browse another site at the same time. It’s important to note that while you may still see our logo and frame, any information you provide to a third party is not covered by our privacy or security policies.
If you have questions or concerns about linked third parties’ privacy policies and practices, please review their websites and contact them directly. This privacy policy applies solely to information collected by this institution.
Security
People Driven Credit Union and its service providers have developed strict policies and procedures to safeguard your personal information. We restrict employee access to your sensitive personal information on a “need to know” basis. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your non-public personal information. We educate our employees about the importance of confidentiality and customer privacy. We take appropriate disciplinary measures to enforce employee privacy responsibilities.
Our internet banking service provider has developed a top-of-the-line security system to protect your customer information on the Internet and within the data center environment.
Privacy of Children
We respect the privacy of children. We do not knowingly collect names, email addresses, or any other personally identifiable information from children. We do not knowingly market to children.
Our website may include linked third-party sites that would be of interest to children. We are not responsible for the privacy and security practices of these sites. Parents should review the privacy policies of these sites closely before allowing children to provide any personally identifiable information.
Privacy Updates
New product releases may require changes to our Privacy Policy. The effective date of our policy will always be clearly displayed. Suppose we make any changes regarding using or disclosing your personal information. In that case, we will provide you with prior notice and the opportunity to opt out of such disclosure if required by law.
Questions
If you have any questions about our privacy policy or concerns about our privacy practices, please contact us.
