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CALIFORNIA PRIVACY NOTICE

This California Privacy Notice ("California Notice”) supplements the Online Privacy Policy and the Consumer Privacy Notice, and applies to you only if you are a resident of the State of California. The terms "Bethpage," "we," "our," and "us" in this California Privacy Notice refer to Bethpage Federal Credit Union and/or its affiliates or subsidiaries, and we have adopted this California Notice to comply with California privacy laws, including the California Consumer Privacy Act ("CCPA”).


Table of Contents
I. NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION
II. YOUR CALIFORNIA PRIVACY RIGHTS
III. SUBMITTING A VERIFIED CONSUMER REQUEST
IV. SALE OF PERSONAL INFORMATION
V. MODIFICATIONS AND UPDATES TO THIS CALIFORNIA NOTICE
VI. ADDITIONAL INFORMATION AND ASSISTANCE

I. NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION

We collect certain information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you ("Personal Information”), as further described below. In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not Personal Information. To the extent this data is stored or associated with Personal Information, it will be treated as Personal Information; otherwise, the data is not subject to this notice.

Categories of Personal Information:

In the last twelve (12) months, we have collected the following categories of Personal Information:

  1. Personal Identifiers, including those listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)), such as a real name, account name, signature, social security number, physical characteristics or description, mailing address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, and other financial information, email address, online identifier, internet protocol (IP) address, device type, mobile device identifier, and other similar identifiers.
  2. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  3. Internet or other electronic network activity information, such as the pages visited; the sites used before or after visiting ours; your actions within the Services; the type of content or advertisements accessed, seen, forwarded and/or clicked on; Wi-Fi connections; date and time stamps; log files; and diagnostic, crash, website, and performance logs and reports.
  4. Geolocation data.
  5. Professional or employment information, such as title, salary, employment records, and references.
  6. Education information, such as details of your education history and qualifications.
  7. Audio, electronic, and similar information, such as calls and messages on our customer service phone line.
  8. Inferences drawn from any of the information above to create a profile about an individual reflecting the individual’s preferences, characteristics, and transaction behavior.

We will not collect additional categories of Personal Information other than those categories listed above. If we intend to collect additional categories of Personal Information, we will provide you with a new notice at or before the time of collection.

Use of Personal Information:

We collect and process your Personal Information for the following business and commercial purposes:

  • To personalize your experience on the Site
  • To allow you to apply for products or services and to evaluate your eligibility for such products or services
  • To respond to your inquiries and fulfill your requests
  • To inform you about important information regarding the Site, products, or services for which you have enrolled in, applied for, or may be interested in applying for, as well as changes to terms, conditions, and policies, and/or other administrative information
  • To deliver marketing communications that may be of interest to you, including advertisements or offers tailored to you
  • To verify your identity and/or location in order to allow access to your accounts, conduct online transactions, and to prevent fraud and protect the security of your information and the Site
  • To allow you to participate in surveys and other forms of market research, sweepstakes, contests, and similar promotions and to administer these activities
  • To comply with laws and regulations, and to comply with other legal process and law enforcement requirements
  • To recognize your device and to allow you to use online products and services
  • To remember your personal settings including preferences and otherwise personalize your experience on the Site
  • To facilitate navigation of the Site and ensure technological compatibility with your device
  • To display information more effectively and understand how account holders and visitors use the Site
  • To improve our products and services
  • To provide advertisements and marketing offers and measure the effectiveness of our advertisements and content
  • To ensure the Site functions properly
  • For fraud detection and prevention and security purposes
  • To collect statistical information and conduct aggregate analyses on usage patterns of the Site and response rates
  • To help diagnose server problems
  • To help determine which advertisements and offers to present and to make those advertisements and offers more relevant or of interest you

We will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with notice.

Sources of Personal Information

We collect Personal Information from the following categories of sources:

  • Information You Choose to Submit. We receive and store any information you enter on the Site or when you contact us or otherwise communicate with us, such as information provided through forms, surveys, applications, other online fields, or given to us in any other way.
  • Information from Service Providers and Public Sources. We may obtain information that is publicly available, and we contract with certain other parties to provide certain services to allow us to provide our services and operate our business.
  • Information from your Browser or Device. Most browsers and devices collect and share certain information, such as Internet Protocol (IP) address, device type, screen resolution, operating system version, internet browser type and version, and geo-location of the device.
  • Information Collected Through Cookies - Like many websites, we use cookies to enhance your experience on the Site. Cookies are small text files that are placed on your computer or device to distinguish you from other visitors to the Site. We and/or our third-party advertising providers may place cookies or similar files on your hard drive to collect or track information about your activities while using the Site, including time spent on the Site, pages visited, and your relationship with us. For more information on cookie usage, see our Online Privacy Policy.
  • From our Data Analytics Providers. For example, we and our technology providers automatically collect data related to your use of the Services through the use of logging and analytics tools (such as Google Analytics), cookies, web beacons (transparent graphical images placed on a website), pixel tags, Flash objects and other tracking technologies and as a result of your use of and access to the Site, such as the pages you visit, the sites you use before or after visiting ours, your actions within the Site, the type of content or advertisements you have accessed, seen, forwarded and/or clicked on, Wi-Fi connections, date and time stamps, log files, and diagnostic, crash, website, and performance logs and reports.
  • Advertising Providers. Our third-party advertising services (such as Facebook and DoubleClick) use cookies, web beacons, pixel tags, Flash objects and other tracking technologies to collect information about your online activity and provide online behavioral advertising.

Sharing of Personal Information

Within the last twelve (12) months, we have shared the following categories of CCPA-subject Personal Information for a business purpose with the following categories of third parties (See Categories of Personal Information):

  • Category 1 (e.g. Identifiers): Advertising Providers (as described above)
  • Category 2 (e.g. Commercial Information): Advertising Providers
  • Category 3 (e.g. Online Activities): Advertising Providers
  • Category 4 (e.g. Geolocation Data): Advertising Providers

In addition, we share Personal Information that is not subject to CCPA as provided in our Consumer Privacy Notice, which also includes information on how to opt out of or limit the sharing of certain information.

Finally, we may share your Personal Information: (i) in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law; (ii) when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Consumer Member Account Agreement and our Business Member Account Agreement and other agreements; or (iii) in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

II. YOUR CALIFORNIA PRIVACY RIGHTS

The CCPA provides California residents with the following rights with respect to certain CCPA-subject Personal Information:

  1. Right to Know: You have the right to request that we disclose certain information to you about the Personal Information we collected, used, disclosed, and sold about you in the past twelve (12) months. This includes a request to know any or all of the following:
    • The categories of Personal Information collected about you;
    • The categories of sources from which we collected your Personal Information;
    • The categories of Personal Information that we have sold or disclosed about you for a business purpose;
    • The categories of third parties to whom your Personal Information was sold or disclosed for a business purpose;
    • Our business or commercial purpose for collecting or selling your Personal Information; and
    • The specific pieces of Personal Information we have collected about you.
  2. Data Portability: You have the right to request a copy of Personal Information we have collected and maintained about you in the past twelve (12) months.
  3. Right to Deletion: You have the right to request that we delete Personal Information we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your Personal Information, we may deny your request or may retain certain elements of your Personal Information as permitted by law, including:
    • Personal Information that is not subject to the CCPA.
    • To complete the transaction for which the Personal Information was collected, provide a product or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.
    • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
    • To debug to identify and repair errors that impair existing intended functionality.
    • To 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.
    • To comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
    • To 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 the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
    • To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
    • To comply with a legal obligation.
    • To otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
  4. Right to Opt-Out/In: You have the right to opt-out of the sale of your Personal Information. You also have the right to opt-in to the sale of Personal Information. Please see our Notice of Right to Opt-Out on our Do Not Sell My Personal Information page for more information about your opt-out/in rights.
  5. Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights.

Some of our products and services, however, may require your Personal Information. If you choose not to provide your Personal Information that is necessary to provide any aspect of our products or services, you may not be able to use those products or services.

III. SUBMITTING A VERIFIED CONSUMER REQUEST

To exercise your Right to Know, Data Portability, and Right to Delete, you must provide us with sufficient information to allow us to verify your identity, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Once we receive the information you provide to us, we will review it and determine if more information is necessary to verify your identity as required by law, and we may request additional information in order to do so.

To exercise your California privacy rights described above, please submit a verifiable request to us by:

Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for Right to Know or Data Portability twice within a twelve (12)-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We will need to verify your identity with at least two (2) pieces of information, such as name and email address.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. We will only use Personal Information provided in a verifiable consumer request to verify the request’s identity or authority to make the request.

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

We will acknowledge receipt of the request within ten (10) business days of its receipt. We will respond to a verifiable consumer request within forty-five (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. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. 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 unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Consumer Request by an Authorized Agent

If any authorized agent submits a consumer request on your behalf, in order to confirm that person or entity’s authority to act on your behalf and verify the authorized agent’s identity, we require the below items:

  • To verify your authorization to request on behalf of a California resident, provide one or more of the following: (1) California Secretary of State authorization, (2) written permission from the California resident, or (3) power of attorney.
  • Sufficient information to verify the authorized agent’s identity, depending on the nature of the request.
  • To verify the identity of the California resident for whom the request is being made, provide the information set forth above for verification of the consumer request.

IV. SALE OF PERSONAL INFORMATION

We do not sell your Personal Information that is subject to the CCPA to third parties for money. However, the CCPA defines "sale” broadly, and that definition could include information that we have shared with certain technology providers that provide certain services to us, including delivering advertisements that we believe may be of interest to you. In the past twelve (12) months, we have "sold” (as defined under the CCPA) the following categories of Personal Information that is subject to the CCPA to the following categories of third parties (See Categories of Personal Information):

  • Category 1 (e.g. Identifiers): Advertising Providers
  • Category 2 (e.g. Commercial Information): Advertising Providers
  • Category 3 (e.g. Online Activities): Advertising Providers
  • Category 4 (e.g. Geolocation Data): Advertising Providers

We "sell” (as defined under the CCPA) your Personal Information for the following business or commercial purposes:

  • Marketing our products and services to you, including sending you promotional or marketing communications, which may include contests, promotions, and special offers for products and services.
  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions.

We do not and will not knowingly sell the CCPA-subject Personal Information of minors under the age of 16.

Do Not Track

We use analytics systems and providers and participate in advertising networks that process Personal Information about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We are not currently able to, and do not, process or comply with any web browser’s "do not track” signal or similar mechanisms.

Note, however, that you may find information about how to opt out of or block certain technologies as described under Automatically Collected Information in our Online Privacy Policy.

V. MODIFICATIONS AND UPDATES TO THIS CALIFORNIA NOTICE

This California Notice is subject to change. It is your responsibility to review this California Notice and remain informed about any changes to it. Any changes to this California Notice will become effective when we post the revised California Notice on the Site. Your use of the Site following these changes constitutes acceptance of any amendments to and the most recent of this California Notice.

VI. ADDITIONAL INFORMATION AND ASSISTANCE

If you have any questions or concerns about this California Notice and/or how we process Personal Information, please contact us at: privacy@bethpagefcu.com.

Last Updated: September 1, 2021