Phi Beta Sigma Federal Credit Union Website Privacy
Policy
(a) NIST Privacy Framework
(b) Phi Beta Sigma Federal
Credit Union Database Credentials Coding Policy
(c) Phi Beta
Sigma Federal Credit Union Server Security Policy
(d) How To Comply with the Privacy of Consumer Financial Information Rule
of the Gramm-Leach-Bliley Act
Last updated: December 7, 2020
INTRODUCTION
Phi Beta Sigma Federal Credit Union (“we” or “us” or “our”) respects the
privacy of our users (“user” or “you”) of our online or mobile services
(collectively, the "Services"). The policy refers to both the
information used in accessing the website and submitted in using the CU
services. This Privacy Policy
explains how we collect, use, disclose, and safeguard your information when you
visit our website pbsfcu.org [and our mobile application
(currently under development)],
including any other media form, media channel, mobile website, or mobile
application related or connected thereto (collectively, the “Site”). Please
read this privacy policy carefully. If you do not agree with the terms of this
privacy policy, please do not access the site.
We reserve the right to make changes to this Privacy Policy at
any time and for any reason. We will alert you about any changes by updating
the “Last Updated” date of this Privacy Policy. Any changes or modifications
will be effective immediately upon posting the updated Privacy Policy on the
Site, and you waive the right to receive specific notice of each such change or
modification.
You are encouraged to periodically review this Privacy Policy to
stay informed of updates. You will be deemed to have been made aware of, will
be subject to, and will be deemed to have accepted the changes in any revised
Privacy Policy by your continued use of the Site after the date such revised
Privacy Policy is posted.
COLLECTION OF YOUR INFORMATION
We may collect information about you in a variety of ways. The
information we may collect on the Site includes:
Personal Data
Personally identifiable information, such as your name, social
security number, date of birth, driver’s license, email address, and telephone
number, and demographic information, such as your age, gender, hometown, and
interests, that you voluntarily give to
us when you register with the Site [or our mobile application,] or] when you
choose to participate in various activities related to the Site [and our mobile application],
such as such as membership application and loan application, online chat and message boards. You are
under no obligation to provide us with personal information
of any kind, however your refusal to do so may prevent you from using certain
features of the Site and Services, [and our mobile application].
Derivative Data
Information our servers automatically collect when you access
the Site, such as your IP address, your browser type, your operating system,
your access times, and the pages you have viewed directly before and after
accessing the Site. [If you are using our mobile application, this information
may also include your device name and type, your operating system, your phone
number, your country, your likes and replies to a post, and other interactions
with the application and other users via server log files, as well as any other
information you choose to provide.]
Financial Data
Financial information, such as data related to your
payment method (e.g. valid credit card number, card brand, expiration date)
that we may collect when apply for membership, make a share deposit or loan payment and
information required and obtained from credit reports[or our mobile application].
Data From Social Networks
User information from social networking
sites, such as [
Facebook, Google+, Instagram, Pinterest, Twitter], including your name,
your social network username, location, gender, birth date, email address,
profile picture, and public data for contacts, if you connect your account to
such social networks. [If
you are using our mobile application, this information may also include the
contact information of anyone you invite to use and/or join our mobile
application.]
Mobile Device Data
Device information, such as your mobile device ID, model, and
manufacturer, and information about the location of your device, if you access
the Site from a mobile device.
Third-Party Data
Information from third parties, such as personal information or
network friends, if you connect your account to the third party and grant the
Site permission to access this information.
Mobile Application Information
If you connect using our mobile application:
USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you
with a smooth, efficient, and customized experience. Specifically, we may use
information collected about you via the Site [or our mobile application] to:
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain
situations. Your information may be disclosed as follows:
By Law or to Protect Rights
If we believe the release of information about you is necessary
to respond to legal process, to investigate or remedy potential violations of
our policies, or to protect the rights, property, and safety of others, we may
share your information as permitted or required by any applicable law, rule, or
regulation. This includes exchanging information with other entities for fraud
protection and credit risk reduction.
Third-Party Service Providers
We may share your information with third parties that perform
services for us or on our behalf, including payment processing, data analysis,
email delivery, hosting services, customer service, and marketing assistance.
Marketing Communications
With your consent, or with an opportunity for you to withdraw
consent, we may share your information with third parties for marketing
purposes, as permitted by law.
Online Postings
When you post comments, contributions or other content to the Site [or our mobile applications],
your posts may be viewed by all users and may be
publicly distributed outside the Site [and our mobile application] in perpetuity.
Third-Party Advertisers
We may use third-party advertising companies to serve ads when
you visit the Site [or our mobile application]. These companies may use information about your visits to the
Site [and our mobile application] and other
websites that are contained in web cookies in order to provide advertisements
about goods and services of interest to you.
Affiliates
We may share your information with our affiliates, in which case
we will require those affiliates to honor this Privacy Policy. Affiliates
include our parent company and any subsidiaries, joint venture partners or
other companies that we control or that are under common control with us.
Business Partners
We may share your information with our business partners to
offer you certain products, services or promotions.
[Social Media Contacts
If you connect to the Site [or our mobile application]
through a social network, your contacts on the social network will see your
name, profile photo, and descriptions of your activity.
Other Third Parties
We may share your information with advertisers and investors for
the purpose of conducting general business analysis. We may also share your
information with such third parties for marketing purposes, as permitted by
law.
Sale or Bankruptcy
If we reorganize or sell all or a portion of our assets, undergo
a merger, or are acquired by another entity, we may transfer your information
to the successor entity. If we go out of business or enter bankruptcy, your
information would be an asset transferred or acquired by a third party. You
acknowledge that such transfers may occur and that the transferee may decline
honor commitments we made in this Privacy Policy.
We are not responsible for the actions of third parties with
whom you share personal or sensitive data, and we have no authority to manage
or control third-party solicitations. If you no longer wish to receive
correspondence, emails or other communications from third parties, you are
responsible for contacting the third party directly.
TRACKING TECHNOLOGIES
Cookies and Web Beacons
We may use cookies, web beacons, tracking pixels, and other
tracking technologies on the Site [and our mobile application] to help customize
the Site [and our mobile application] and improve your experience. When you access the Site [or our mobile application],
your personal information is not collected through
the use of tracking technology. Most browsers are set to accept cookies by
default. You can remove or reject cookies
but be aware that such action could affect the
availability and functionality of the Site [or our mobile
application]. You may not decline web beacons. However, they can be rendered
ineffective by declining all cookies or by modifying your web browser’s
settings to notify you each time a cookie is tendered, permitting you to accept
or decline cookies on an individual basis.
[We may use cookies, web beacons, tracking pixels, and other
tracking technologies on the Site [and our mobile application] to help customize
the Site [and our mobile application] and improve your experience. For more information on how we use
cookies, please refer to our Cookie Policy posted on the Site, which is
incorporated into this Privacy Policy. By using the Site, you agree to be bound
by our Cookie Policy.]
Website Analytics
We may also partner with selected
third-party vendors[, such as [Adobe Analytics,] [Clicktale,] [Clicky,] [Cloudfare,] [Crazy Egg,] [Flurry Analytics,] [Google Analytics,] [Heap Analytics,] [Inspectlet,] [Kissmetrics,] [Mixpanel,] [Piwik,] and others], to
allow tracking technologies and remarketing services on the Site [and
our mobile application] through
the use of first party cookies and third-party
cookies, to, among other things, analyze and track users’ use of the Site [and
our mobile application], determine the popularity of certain content and
better understand online activity. By accessing the Site [,our mobile application,],
you consent to the collection and use of your
information by these third-party vendors. You are encouraged to review their
privacy policy and contact them directly for responses to your questions. We do
not transfer personal information to these third-party vendors. However, if you
do not want any information to be collected and used by tracking technologies,
you can visit the third-party vendor or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.
You should be aware that getting a new computer, installing a
new browser, upgrading an existing browser, or erasing or otherwise altering
your browser’s cookies files may also clear certain opt-out cookies, plug-ins,
or settings.
THIRD-PARTY WEBSITES
The Site [and our mobile application] may contain links to
third-party websites and applications of interest, including advertisements and
external services, that are not affiliated with us. Once you have used these
links to leave the Site [or our mobile application], any information you
provide to these third parties is not covered by this Privacy Policy, and we
cannot guarantee the safety and privacy of your information. Before visiting
and providing any information to any third-party websites, you should inform
yourself of the privacy policies and practices (if any) of the third party
responsible for that website, and should take those steps necessary to, in your
discretion, protect the privacy of your information. We are not responsible for
the content or privacy and security practices and policies of any third
parties, including other sites, services or applications that may be linked to
or from the Site [or our mobile application].
SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures
to help protect your personal information. While we have taken reasonable steps
to secure the personal information you provide to us, please be aware that
despite our efforts, no security measures are perfect or impenetrable, and no
method of data transmission can be guaranteed against any interception or other
type of misuse. Any information disclosed online is vulnerable to interception
and misuse by unauthorized parties. Therefore, we cannot guarantee complete
security if you provide personal information.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems [and
our mobile applications] include a Do-Not-Track (“DNT”) feature or setting you can
activate to signal your privacy preference not to have data about your online
browsing activities monitored and collected. No uniform technology standard for
recognizing and implementing DNT signals has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard
for online tracking is adopted that we must follow in the future, we will
inform you about that practice in a revised version of this Privacy Policy. Most
web browsers and some mobile operating systems [and our mobile applications] include a Do-Not-Track (“DNT”) feature or setting you can
activate to signal your privacy preference not to have data about your online
browsing activities monitored and collected. If you set the DNT signal on your
browser, we will respond to such DNT browser signals.
OPTIONS REGARDING YOUR INFORMATION
[Account Information]
You may at any time review or change the information in your
account or terminate your account by:
Upon your request to terminate your account, we will deactivate
or delete your account and information from our active databases. However, some
information may be retained in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our Terms of Use and/or
comply with legal requirements.
Emails and Communications
If you no longer wish to receive correspondence, emails, or
other communications from us, you may opt-out by:
If you no longer wish to receive correspondence, emails, or
other communications from third parties, you are responsible for contacting the
third party directly.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine
The Light” law, permits our users who are California residents to request and
obtain from us, once a year and free of charge, information about categories of
personal information (if any) we disclosed to third parties for direct
marketing purposes and the names and addresses of all third parties with which
we shared personal information in the immediately preceding calendar year. If
you are a California resident and would like to make such a request, please submit
your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have
a registered account with the Site [or our mobile application], you have the right
to request removal of unwanted data that you publicly post on the Site [or
our mobile application]. To request removal of such data, please contact us using the
contact information provided below, and include the email address associated
with your account and a statement that you reside in California. We will make
sure the data is not publicly displayed on the Site [or our mobile application],
but please be aware that the data may not be
completely or comprehensively removed from our systems.
CONTACT US
If you have questions or comments about this Privacy Policy,
please contact us at:
Phi Beta Sigma Federal Credit Union
145 Kennedy Street NW Washington, DC 20011
Phone: (202) 726-2285
Fax: (202) 726-5814
Email: MemberServices@pbsfcu.org or
LoanServices@pbsfcu.org
