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First Financial Credit Union and its wholly-owned affiliate, TSA Special Member & Insurance Services, Inc., understand the importance of protecting the financial privacy of our members and customers. As such, we are committed to maintaining the confidentiality of your financial records consistent with state and federal laws. The following sets forth our policies regarding our use and protection of your financial information.
Section I: Collection and Use of Information
During the course of business, we collect the information you provide to us as well as information available from public records and credit reports. We use this information about you to administer your records and accounts, to process your transactions, to assist us in developing new products and services, to aid you in learning more about our products and services, and to fulfill any legal and regulatory requirements. We collect information about you from the following sources:
- Information we receive from you in person, on applications or by other means.
- Information about your transactions with us or our Affiliates (“Transaction/Experience Information”).
- Information obtained by verifying representations made by you.
- Information we receive from a consumer reporting agency.
- Information we receive from outside sources, such as public records or third parties.
Section II: Sharing Information with Third Parties
We may disclose all of the information we collect, as described above, to companies that perform services on our behalf, such as check‑printing and data processing companies. Generally, we may share your information with non‑affiliated third parties to complete transactions and to maintain your accounts and related records (such as data processing transactions and records). We may also share information with third parties if: 1) you request or authorize it; 2) the information is provided to help complete a transaction initiated by you; 3) the information is provided to a consumer reporting agency in accordance with the Fair Credit Reporting Act; or 4) the disclosure otherwise is lawfully required or permitted.
Under certain circumstances we may also enter into joint marketing agreements to provide the information we collect with other financial institutions in order to offer a greater selection of financial products and services. Before entering into relationships with such entities, we require them to agree to safeguard our members’ information and to comply with all applicable privacy laws. Of course, if you do not wish for us to share your non-public personal information with other financial institutions for joint marketing purposes, you have the right to opt out at any time. Please see the section below entitled “Your Right to Opt Out.”
There are several types of third parties with whom we may share your information. We may disclose non-public personal information about you to the following types of affiliated and non-affiliated third parties:
- Financial service providers, such as mortgage bankers, securities broker‑dealers, and insurance agents; and,
- Non‑financial companies, such as marketing agencies, statement printers, and mailing houses.
We may also disclose non-public personal information about you to non-affiliated third parties not described above, as permitted by law.
Section III: Information Sharing in the Event of Termination of Membership
If you decide to terminate your membership or become an inactive member, we will adhere to the privacy policies and practices as described in this notice, as amended from time to time.
Section IV: Security of Information
We restrict access to non-public personal information about you to those employees who need to know that information to provide products or services to you. Our employees access information about you when needed to administer your accounts, to provide requested services, or in response to a legally valid outside request or order (such as a subpoena). Our employees may also access information to exercise our rights under the law or pursuant to any agreement with you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your non-public personal information. We also continually update and assess our systems to improve our technology for protecting information.
Section V: Accuracy of Information
We strive to ensure that our records contain accurate information about you. If you see any inaccuracies in your statements, please call us toll-free at (800) 537-8491 from 7:00 a.m. to 7:00 p.m., Pacific Time, Monday - Friday. We will promptly investigate and make any necessary changes to update your records.
Section VI: Changes to Our Policy
We reserve the right to revise our policy as our business needs change or as the law requires. If we revise our policies, we will provide our active members with copies of our new policies at that time.
Section VII: The Fair Credit Reporting Act
The Fair Credit Reporting Act ("FCRA") regulates the sharing of information between the Credit Union and the Credit Union's Affiliates and non-affiliated third parties.
The FCRA permits the us to share the following types of transaction and experience information: identification information about you; information about your transactions with us or our Affiliate(s); and information about the our experiences or our Affiliate(s)’ experiences with you (collectively referred to as "Transaction/Experience Information"). Examples of Transaction/Experience Information include your account balances and your credit history with us. It is our practice to share Transaction/Experience Information to administer your accounts and to provide you with enhanced products and services and other opportunities.
In addition, the FCRA permits the Credit Union and its Affiliate(s) to share with each other types of information that bear on your creditworthiness, character, personal characteristics, mode of living, etc. ("Other Information"). Examples of Other Information include information we receive about you from credit reports or from your applications. Other Information does not include Transaction/Experience Information. Under the FCRA, you have the right to request that the Credit Union and its Affiliate(s) discontinue sharing of such Other Information with each other. If you wish to exercise this right, please see the section below entitled “Your Right to Opt Out.” Please note that even if you opt out, the FCRA permits us to continue sharing Transaction/Experience Information with our Affiliate(s) and non‑affiliated third parties to the extent permitted by law.
Section VIII: Your Right to Opt Out
We understand that there are certain third parties with whom you do not wish for us to share your information. If you do not wish for us to share your information with financial institutions for joint-marketing purposes, you have the right to opt out at any time. To opt out of such sharing practice, complete the attached “Important Privacy Choices for Consumers” document, checking the box entitled “Restrict Information Sharing With Other Companies We Do Business With To Provide Financial Products And Services,” and fax or mail the form as indicated.
If you do not wish for us to share “Other Information” with our Affiliates, complete the attached “Important Privacy Choices for Consumers” document, checking the box entitled “Restrict Information Sharing With Companies We Own or Control (Affiliates),” and fax or mail the form as indicated.
You may also exercise the above opt-out rights by toll-free telephone in the manner indicated on the attached form.
If you obtain a financial product or service (other than a loan) from us jointly with another person(s) ("joint consumers"), we may provide only a single opt-out notice to you or the joint consumer. If we receive a direction to opt out by you or by the joint consumer, we will treat the opt-out direction as automatically applying to both you and all of the associated joint consumers.
If you wish to exercise
any of your opt-out rights as described above, you may opt out in
one of three ways:
- Complete an opt-out
form and return it by mail to First Financial Credit Union, Attention:
Corporate Administration, P.O. Box 90, West Covina, CA 91793-0090.
(Click here to download and
print form)
- Call us toll-free
at (800) 537-8491 from 7:00 a.m. to 7:00 p.m., Pacific Time, Monday-Friday,
or 9:00 a.m. to 1:30 p.m., Pacific Time, Saturday.
- Complete an opt-out
form and fax it to us at (626) 814-2689. (Click
here to download and print form)
If you obtain a financial
product or service (other than a loan) from us jointly with another
person(s) ("joint consumers"), we may provide only a single
opt-out notice to you or the joint consumer. If we receive a direction
to opt out by you or by the joint consumer, we will treat the opt-out
direction as automatically applying to both you and all of the associated
joint consumers.
Section IX: Effective Date
The effective date
of this policy is July 1, 2007
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