1. IMPORTANT INFORMATION AND WHO WE ARE
The Site is offered and available to users who have reached the age of majority in the applicable jurisdiction, and AmeriCU does not knowingly collect personal information from users who have not reached the age of majority in the applicable jurisdiction. If we learn that we have collected personal data of a person under the age of majority, depending on jurisdiction, we will take steps to delete the data as soon as possible.
CALIFORNIA RESIDENTS’ RIGHTS
California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact our DPO (contact information provided below).
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
RESPONSIBILITY FOR EXTERNAL SITES
2. THE DATA WE COLLECT ABOUT YOU
“Personal data” or “personal information” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital title, primary job function, company.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes account details, income details and payment card details.
- Transaction Data includes details about payments to and from you and other details of financial products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site.
- Profile Data includes your username and password, purchases or orders made by you, the type of business you are involved in, the types of vehicles/equipment serviced, other details about your business, your preferences, feedback and survey responses.
- Usage Data includes information about how you use the Site, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA?
Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- For our everyday business purposes – to process your transactions and claims, maintain your accounts, report to credit bureaus and facilitate services provided by contracted parties such as mailing services
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- For internal reporting and analytics – to analyze our financial health, forecast profitability, determine trends and otherwise assess our products and services
Compliance with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- To respond to court orders, government investigations, subpoenas and litigation
With your consent.
- For our marketing purposes – to offer products and services provided by AmeriCU
We do not collect any data about you identified under the GDPR as “Special Categories of Personal Data” (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, personal or political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses. If we learn that we have such collected personal data, we will take steps to delete the data as soon as possible.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, under the terms of a contract we have with you, or otherwise, and you fail to provide that data when requested, we may not be able to sell products or services to you. In this case, we may have to cancel a product or service contract you have with us, but we will notify you if this is the case.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
If the personal data we are collecting from you is subject to the GDPR, we will use our best efforts to collect your personal data pursuant to GDPR required standards. We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms in person or online or by communicating with us by mail, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on the Site;
- request marketing materials to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with the Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may use third party analytics services like Google Analytics to provide us with a clearer picture of how you use the Site, including when you view specific pages or take specific actions on the Site. For more information about Google Analytics or to opt-out of Google Analytics, please go to Google Analytics Opt-Out Settings page here. If you wish to learn more about our data collection process, please contact our DPO (contact information provided below).
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. If you are in the European Union, or if your personal data otherwise may be subject to the GDPR, you should understand that we will use our technical infrastructure in the United States in order to deliver various services to you. If you are purchasing goods or services through the Site, we may need to transfer your personal data to the United States, and possibly to other jurisdictions outside of your home country, as necessary to provide these services. Similarly, if you are browsing the Site, we may collect certain personal data about you in order to enhance the Site, and your experience on the Site. Processing of your personal data as you browse the Site is necessary for our legitimate interests, and we believe these interests will not interfere with your fundamental rights or freedoms. Most commonly, we will use your personal data in the following circumstances:
- Where we need to sell products or services to you or are about to enter into or have entered a contract with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- To enforce or apply our Terms and Conditions and/or any other agreements, including for billing and collection purposes.
If the personal data we collect from you is subject to the GDPR, we will attempt to process your data pursuant to the lawful bases of the GDPR.
If your personal data is subject to the GDPR, please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). In addition, we may share such data with authorized third parties who we contract with to provide marketing services on our behalf, unless you opt out of receiving marketing messages, as set forth below. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
You may receive marketing communications from us or third parties we have contracted with to provide marketing services on our behalf if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing communications at any time by following the opt-out links on any marketing message sent to you or by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If your personal data is subject to the GDPR, and we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. SHARING AND DISCLOSURE OF YOUR PERSONAL DATA
6. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. However, no transmission of data via the internet or electronic storage of information can be completely secure, so any transmission of personal data or other data is at your own risk.
All personal data you provide to us through the Site is stored on a secure server and protected by firewalls.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
7. DATA RETENTION
HOW LONG WILL YOU KEEP MY PERSONAL DATA?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period, if required by law, in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we may consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We may anonymize your personal data (so that it can no longer be associated with you) for research, statistical purposes, or other purposes, in which case we may use this information indefinitely without further notice to you.
8. YOUR LEGAL RIGHTS
If your personal data is subject to the GDPR, you have certain rights in relation to your personal data. Such rights may include the right, under certain circumstances, to: (1) request access to your personal data, (2) request correction of the personal data that we hold about you, (3) request erasure of your personal data, (4) object to processing of your personal data, (5) request restriction of processing of your personal data,(6) request the transfer of your personal data or (7) withdraw your consent at any time where we are relying on consent to process your personal data.
AmeriCU Credit Union
Email address: firstname.lastname@example.org
Mailing address: ATTN: Privacy, 1916 Black River Blvd., Rome NY 13440
Telephone number: 800.388.2000