Central Willamette Community Credit Union

PRIVACY STATEMENT

CENTRAL WILLAMETTE COMMUNITY CREDIT UNION
CENTRAL WILLAMETTE FINANCIAL SERVICES
PRIVACY POLICY

Our Privacy Pledge. At Central Willamette Community Credit Union, we respect the privacy of our members. We recognize the importance of maintaining the confidentiality of your personal financial information. This notice describes the privacy policy and practices followed by Central Willamette Community Credit Union and our affiliate, Central Willamette Financial Services. This notice explains what types of member information we collect and under what circumstances we may share it.

Elaine Eastman
President/CEO

Member Information We Collect. The Credit Union collects only relevant information about members that is needed to establish and maintain your account and services as the law allows or requires us to collect. We may collect personal and financial information about you (member information) which is "nonpublic." The member information we collect varies depending on the accounts and services you request and use. We collect information about you from the following sources:

Application Information. We retain personal information we receive from you on any application you provide for membership, deposit account, EFT services, loans, financial planning, securities brokerage, insurance, or other Credit Union services. This information includes: name, address, social security number, birth date, phone number, employment and financial status, and credit history.

Your Transactions. Any time you make a transaction on one of your accounts, including ATM or card transactions, loan advances, transactions through CU Online, over the phone, or at a branch we retain the transaction information, including: your account number, the date, amount, location of the transaction, and other pertinent information.

Credit Reports. When we evaluate your application for an account or service, we may request a credit report about you from a consumer reporting agency. We retain the personal and credit history information about you and we may use it to evaluate future account service requests.

Online. We obtain information online when you visit our website, www.centralwcu.org. This includes retaining information you provide us on any online application, CU Online transaction, or information you send to us by e-mail.

Member Information We Share. In order to provide financial services to you, we share certain information about you with our affiliates and third party service providers. However, we only share information to the extent necessary to service your account or offer new services to you. If we share your information, it is with the goal of bringing you quality services, more choices, and greater convenience. Information we may have about former members is generally only shared or disclosed if necessary to enforce or administer an account or as required by law.

Sharing Information with Credit Union Affiliates. Our wholly-owned affiliate, Central Willamette Financial Services, provides financial services, including financial planning, securities brokerage, and insurance products and services. We may share personal information (such as name, address, account number) and account information (such as type of accounts, account balances, transaction history) with our affiliate so they can serve you more efficiently: Our affiliate maintains the same privacy standards as the Credit Union.

Sharing Information with Third Party Service Providers. In order for us to conduct our operations, including servicing your account or processing your transactions, we need to share information with our service providers, including: data processing companies, check, ATM and other payment processing companies, payment networks, loan service providers, insurance companies, collection agencies, credit reporting agencies, financial planners, securities brokerage, and financial service providers with whom we have joint marketing agreements. These service providers act on our behalf and have agreed in writing to keep the member information we provide to them confidential. We share the following categories of information to third party service providers depending on the specific services provided:

• Personal information (name, address, Social Security  number and account number, etc.)
• Account information (type of accounts, account balances, and transaction history, etc.)
• Transaction information (dates, amounts, locations, and type of transaction, etc.)

We do not sell member information nor share your account numbers with independent third party marketers offering their products and services. While we may assist in offering financial products and services of our affiliate or other financial service providers, we control the member information used to make such offers.

Sharing Information as Legally Required or Permitted. We may share any member information of yours in response to a lawful request issued by a court, government agency, or regulatory authority or as permitted by law in order to administer or enforce your account. We may also share our experience information about you with credit bureaus. Our reporting to credit bureaus is governed by the Fair Credit Reporting Act, which affords you the right to make sure that your credit bureau reports are accurate.

Our Confidentiality and Security Safeguards. We maintain strict policies and security controls to assure that member information in our computer systems and files is protected. Our employees and agents are permitted access to member information that they may need to perform their jobs and to provide service to you. Our employees and agents have access to such member information as necessary to conduct a transaction or respond to your inquiries. All employees and agents are trained to respect member privacy. No one except our employees and agents has regular access to the Credit Union computer system and records storage. The Credit Union has established internal security controls, including physical, electronic and procedural safeguards to protect the information you provide us and the information we collect about you. We will continue to review our internal security controls to safeguard your member information as we employ new technology in the future.

Online Privacy Protections. At our website, www.centralwcu.org, you may apply for accounts and services and you may communicate with us via e-mail. To protect the information you provide us online, we use multiple levels of security. The application information we accept online and our home banking service relies on industry standard "Secure Sockets Layer" (SSL) encryption to secure your transaction information and communication. Generally, our e-mails are not secure. However, if we ask you to e-mail us information other than your name, address, e-mail address and phone number, it will be obtained using a secure (SSL encryption) e-mail form. When you visit our website, you can access site information without revealing your personal identity. However, in order to help us identify you for future site visits, we use "cookies" to track your visit.  Cookies are small text files assigned and attached by a web server to the directory file on your PC.  Cookies help websites recognize return visitors.  So, when you return to a website that you have visited before, your browser gives this data back to the server. We use cookies to make your online experience easier and more personalized.  We use cookies in the following way: CU Online places a cookie on your PC when you log in. It is a temporary cookie that holds a unique number that identifies you only to our server.  It holds no personal information but it is used to authenticate your home banking access.  Various pages on our website also place cookies on your PC when you visit thoses pages.  The purpose of those cookes is to track activity and usage patterns on the site.  These cookies are not personally identifiable.   

Protecting Children's Information Privacy. Our online financial services are not designed for or directed toward children. We do not knowingly solicit or collect data from children and we do not knowingly market to children online. We recognize that protecting children's identities and online privacy is important and that responsibility rests with us and with parents.

Requesting Personal Information Electronically.  The Credit Union will not solicit confidential or sensitive member information via email or online pop-ups.  Due to the fact that perpetrators often use mass-mailing programs to send spam emails to many recipients using non-personalized greeting such as "Valued Member" or "To Whom It My Concern", emails sent to members will use the member's name within the email.  The exception to this policy will be when the Credit Union is responding to an email sent by a member who did provide a name.

Privacy Policy Inquiries. If you have any questions about our privacy practices, contact us by calling (541) 928-4536, sending us an e-mail, or writing to us at Central Willamette Community Credit Union, P.O. Box D, Albany, Oregon 97321.

Central Willamette Community Credit Union
Children's Privacy Statement

Central Willamette Community Credit Union takes the issue of safeguarding your online privacy very seriously, particularly so for our children under the age of 13. Please read the following to understand our views and practices regarding this matter, and how they pertain to you as you make full use of our Website.

Central Willamette has adopted Policy that outlines how we will deal with a child who is under the age of 13 and visits our Website. Central Willamette will:

1. NOT collect online information without prior parental consent or parental notification, which will include an opportunity for the parent to prevent the use of the information and participation in the activity. Without prior parental consent, online information will only be used to respond directly to the child's request and will not be used for any other purpose.
2. NOT collect personally identifiable information without prior parental consent or notification and will not act on or use in any manner any information provided until such consent is given. If consent is not given within 10 business days the information shall be destroyed by the Credit Union and no record maintained.
3. NOT distribute to any third parties, including any wholly owned subsidiaries of the Credit Union, any personally identifiable information of any child under the age of 13.
4. NOT give the ability to publicly post or otherwise distribute personally identifiable contact information without prior parental consent.
5. NOT entice by the prospect of special game, prize or other activity, to divulge more information than is needed to participate in the program or activity.
6. DELETE, at the parents request, any personally identifiable information that has been collected by the Credit Union via its Website at any time. However, the removal of some information might result in a child's account which was opened via the Website, having to be closed as necessary information would no longer exist.

What personal information does the Credit Union collect?

Central Willamette Community Credit Union does not require you to give any personal information to access our Website. Personal information is required to access the features of our Home Banking Services and is required when applying for membership, savings and lending products.

Central Willamette does not contain links to Web sites that may ask for personal information to access the site. We review these sites carefully before including them but the privacy and data collection practices of these, or any other sites listed by the Credit Union are entirely separate from our own site and are not covered by this privacy policy. Central Willamette Community Credit Union has no responsibility or liability for these independent sites' policies or actions.

KIDS: Please be sure you get your parents permission before giving any information about yourself to anyone on the Internet, including the Credit Union.

Central Willamette Community Credit Union does not use cookies on our Website. You may, however, find sites listed on our Website that will place a cookie in your computer's browser file as a way to remember your specific interests and preferences, and to provide you with relevant information each time you visit. Central Willamette has no control over this type of data gathering on linked Websites.

Central Willamette Community Credit Union's site host does collect IP addresses for the purposes of system administration and to report aggregate usage information.

If you have questions about this statement or other Website privacy concerns please contact our Internal Auditor.