Privacy Policy

b. Categories of Cookies

Third-Party Website Cookies That We Cannot Control

When using our websites, you may be directed to other websites for activities such as surveys, completing job applications, and to view content hosted on those sites such as an embedded video or news article. These websites may use their own cookies. We do not have control over the placement of cookies by other websites you visit, even if you are directed to them from our websites.

2) Location Data

When allowed by you, our app collects your location data to provide you with location-based services, such as identifying branches and ATMs near you, and location-based messages and offers. Location access can be allowed once, only while using the app, or you can choose to not allow location data to be collected.

3) IP Addresses

If you log on to our websites to access our online services, including but not limited to the online banking page, you may pass through a “firewall” used for security purposes and the Internet Protocol (IP) address associated with the device you are using may be identified. In certain instances, it may also obtain other information about your device to better identify you as an online user. This information may be retained in case it is needed for security or protection of member information.

4) Social Media

We may collect information, such as your likes, interests, feedback, and preferences when you interact with our official pages on social media websites such as Facebook, X, LinkedIn, YouTube, and Instagram or from our social media partners (but only if you choose to share with them and they, in turn, share that information with us). Please refer to the policies of those companies to better understand your rights and obligations with regard to your activity on those websites.

How We Use Information We Collect

• Laws and regulations. We are a regulated financial institution that is subject to laws and regulations governing our retention of information pertaining to our members, applicants for credit union membership, loans and other financial products and services. We are also an employer and, thus, we are subject to labor laws governing how long we must retain information about applicants for employment and current and former employees. Therefore, applicable laws and regulations will govern how long we retain information pertaining to you.
• Fraud Prevention and Security. We will retain information that we need for fraud prevention and security purposes.
• Contracts. We will retain information for as long as necessary to comply with our contractual obligations to you, our service providers, and other third parties, as permitted by law.
• Legal Claims and Defenses. We may retain information for such a period as necessary or advisable to preserve legal claims and defenses.

U.S. Consumer Privacy Notice

Definitions

Affiliates - Companies related by common ownership or control. They can be financial and non-financial companies. 1st United does not have any affiliates.

Non-affiliates - Companies not related by common ownership or control. They can be financial and non-financial companies. 1st United does not share with non-affiliates so they can market to you.

Joint marketing - A formal agreement between non-affiliated financial companies that together market financial products or services to you. Our joint marketing partners include investment, insurance, and other financial services companies.

Other important information

For California Residents: Please see the Important Privacy Choices for California Members form to exercise opt-out rights that may be available to you under the California Financial Information Privacy Act that otherwise are not under this U.S. Consumer Privacy Notice provided under federal law. You may also have additional privacy rights under our CCPA Privacy Policy.

For Nevada Residents: We are providing this notice pursuant to Nevada law. If you prefer not to receive marketing calls from us, you may be placed on our Internal Do Not Call List by calling (800) 649-0193. You may also contact the Nevada Attorney General’s office: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; telephone number: (702) 486-3132; email aginfo@ag.nv.gov.

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CCPA Privacy Policy

Effective March 1, 2024

This California Consumer Privacy Act Privacy Policy explains how we collect, share, use, and protect your personal information through your online and offline interactions with us. This CCPA Disclosure applies to residents of California to the extent that the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), applies to 1st United Credit Union (also “we,” “us,” and “1st United”).

As used in this Privacy Policy, “personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal Information does not include: (i) publicly available information; (ii) de-identified or aggregated consumer information; or (iii) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”) and the Gramm-Leach-Bliley Act (“GLBA”).

The specific personal information that we collect, use, and disclose relating to a California resident in different contexts covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this CCPA Disclosure does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes (i.e., information subject to the GLBA).

For more information about how we collect, disclose, and secure information relating to these customers, please refer to our U.S. Consumer Privacy Notice. We may use the information described below for any of the purposes described in this CCPA Disclosure or for our business, security, or operational purposes compatible with the context in which the personal information was collected, unless limitations are listed in this CCPA Disclosure or described elsewhere at the time of collection of the information.

I. Categories Of Information We Collect

In the preceding 12 months, we have collected the following categories of personal information (please note that some categories overlap):

In addition to the specific situations discussed elsewhere in this CCPA Disclosure, we may disclose your personal information in the following situations:

• Service Providers. We may share your information with service providers. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, process payments, assist in the fulfillment of services, and help us market our own products and services.
• Joint Marketing Partners. We may share your information with other companies to offer you co-branded financial products and services.
• Advertising Networks. We may share your information with advertising networks such as Google and Facebook to help deliver our advertisements to you as you are browsing online.
• Compliance with Laws and Other Lawful Uses. We may disclose information to law enforcement agencies and other government entities or private parties in litigation in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information with these parties to establish or exercise our rights, to defend against a claim, to investigate, prevent, or act regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
  We may also disclose your personal information with our acquisition or merger partners in the event of an acquisition or merger. Furthermore, we may disclose your personal information as permitted by applicable law. All of the categories of personal information we collect from you may be disclosed for this purpose.
• Your Consent. All the categories of personal information we collect from you may be disclosed to third parties with your consent or direction.

In addition to the information above, California law requires that organizations disclose whether the specific categories of personal information defined in the CCPA have been disclosed to third parties for a “business purpose,” or “sold” or transferred for “valuable consideration,” or “shared” for purposes of cross-context behavioral advertising. The table below indicates which of these specified categories we may collect and transfer in a variety of contexts.

This section describes your rights and choices regarding how we collect, share, use, and protect your personal information, how to exercise those rights, and limits and exceptions to your rights and choices.

a. Exceptions
The rights and choices in this Section do not apply:

• If you are not a California resident;
• If we collected personal information covered by certain financial sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) and/or California Financial Information Privacy Act (“CFIPA”). How we collect, share, use, and protect your personal information is covered under such laws instead of the CCPA; or
• To aggregate consumer information; or
• To de-identified personal information; or
• Publicly available personal information.

b. Right to Know
If the above exceptions do not apply, and you have not made this request more than twice in a 12-month period, you have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your request and verify that the request is coming from you or someone authorized to make the request on your behalf, we will disclose to you or your representative:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting, sharing, or selling that personal information, as applicable.
• The categories of third parties to whom we disclosed, shared, or sold the personal information, as applicable.
• The specific pieces of personal information we collected about you in a form that you can take with you (also called a “data portability request”).

c. Right to Delete
You have the right to request that we delete any of your personal information that we collect from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
2. Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
3. Debug to identify and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
5. Engage in public- or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you previously provided informed consent;
6. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; or
7. Comply with a legal obligation.

d. Right of Correction
You have the right to request correction of any personal information that we retain about you that is incorrect. We generally rely on you to update and correct your personal information.

e. Exercising Access, Data Portability, Deletion and Correction Rights
To exercise the access, data portability, deletion and correction rights described above, you or your authorized agent may submit a verifiable consumer request to us by any of the following methods:

• Call (800) 649-0193.
• Submit a CCPA Submission Form available via this link.
• Email email@1stunitedcu.org. Attach a completed CCPA Submission Form with your email, and do not include any sensitive personal information with your request.
• Mail your request to 1st United Credit Union, 5901 Gibraltar Drive Pleasanton, CA 94588. Include a completed CCPA Submission Form and do not include any sensitive personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

When we receive a verifiable request from your authorized agent we may require:

1. Submission of a written document signed by you with your permission for the authorized agent to submit a verifiable request on your behalf and require the authorized agent to verify its own identity to us; or
2. You may directly verify with us that you have authorized the agent to submit the request.

We will not require either of the above if the authorized agent provides a copy of a power of attorney pursuant to California Probate Code sections 4121 to 4130 and we are able to verify the authorized agent’s identity.

We will deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf and cannot verify their own identity to us.

We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response to the mailing address of record according to our files. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request.

f. Right of Non-Discrimination
We will not discriminate against you for exercising any of your rights in this disclosure and under applicable laws. Unless permitted by law, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price for goods or services or a different level or quality of goods or services.

g. Opt-Out Rights Regarding Sale of Personal Information or Sharing Personal Information for Cross-Context Behavioral Advertising
It is not our policy to sell personal information and we have not done so in the preceding 12-month period. In the preceding 12 months, we have not shared your personal information to third parties for cross-context behavioral advertising purposes.

VI. Changes To This Disclosure
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Disclosure, we will post an updated Privacy Policy on our websites and app.

VII. Contact Information
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights, call (800) 649-0193, email us at email@1stunitedcu.org or mail us at 1st United Credit Union, 5901 Gibraltar Drive Pleasanton, CA 94588.