Ketema Federal Credit Union

Member Privacy Policy Disclosure

Effective 6/30/2009

At Ketema Federal Credit Union we value your privacy. We are grateful that you have chosen to do business with us and we recognize our responsibility for keeping your information secure and confidential. It is the intent of the Credit Union and any of its affiliates to abide by all applicable laws and regulations governing the privacy of nonpublic personal information including NCUA Privacy of Consumer Financial Information rule (Part 716) and the FTC Privacy rule (Part 313) for affiliates, issued to implement the provisions of the Gramm-Leach-Bliley Act and the Right to Financial Privacy Act.

This Privacy Policy Disclosure explains how we protect the privacy of your personal information and when we release information about you under certain situations, such as to maintain your account or other circumstances as required or permitted by law.

As a service to you, we may share information with select third parties that can offer valuable products and services that may interest you.  We do not disclose account numbers. We are required to provide you with the opportunity to opt-out from the disclosure of information to non-affiliated third parties. An opt-out form is included with this notice, is available at the branch and online at www.ketemafcu.com.

Information we collect

In the course of delivering products and services, the Credit Union obtains nonpublic personal information, either directly from the member or from outside sources. This nonpublic personal information is used to comply with federal and state laws and regulations, to provide effective member service and to inform members of products and services which may be of interest to the member. We collect information from the following sources:

(1)           Information you provide to the Credit Union on an application to obtain membership, a loan, credit card or other financial product or service;

(2)           Account balance information, payment history, overdraft history, and credit or debit card purchase information;

(3)           The fact that you are or have been one of the Credit Union’s members or have obtained a financial product or service from the Credit Union;

(4)           Any information about you if it is disclosed in a manner that indicates that you are or have been a member of the Credit Union;

(5)           Any information that a consumer provides to the Credit Union or that the Credit Union or its agent otherwise obtains in connection with collecting on a loan or servicing a loan;

(6)           Any information the Credit Union collects through an Internet “cookie” (an information collecting device from a web server); and

(7)           Information from a consumer report.     

(8)           Information obtained from our sponsoring company (ies) about potential members such as your name and address.

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               Information is collected by the credit union only to the extent necessary to carry out daily business activities and to provide services and other opportunities to our members. We do not have any affiliates. We acquire and keep only that information that we have a reasonable use for or may support current or planned activities. All information gathered may be disclosed only as permitted or required by law.

MAINTENANCE OF ACCURATE INFORMATION. The Credit Union will exercise reasonable caution in the gathering and maintenance of information to ensure its accuracy. When inaccurate information is discovered by us or brought to our attention, it will be corrected as promptly as possible. Prompt notification of any changes in your contact information and your thorough review of your statements is crucial to KFCU’s ability to  maintain accurate information.

DISCLOSING INFORMATION TO THIRD PARTIES. The Credit Union will not disclose personal nonpublic information to third parties without first providing the consumer a clear and conspicuous notice that accurately reflects the Credit Unions privacy policies and practices and providing the consumer a reasonable opportunity to opt out of such disclosure if required(§716.14).

The Credit Union also may share its experience information about the member with credit bureaus. The Credit Union’s reporting to credit bureaus is governed by the Fair Credit Reporting Act, which affords the member the right to make sure that its credit bureau reports are accurate. The requirement for the Credit Union to provide notice and a reasonable opportunity to opt out does not apply if the Credit Union’s disclosure of nonpublic personal information is necessary to effect, administer, or enforce a transaction that a consumer requests or authorizes, or in connection with any of the following (§716.14): 

(A) Servicing or processing a financial product or service that a   consumer requests or authorizes (§716.14).

(B)           Maintaining or servicing the consumer’s account with the Credit Union, or with another entity as part of a private label credit card program or other extension of credit on behalf of such entity (§716.14).

(C)  A proposed or actual securitization, secondary market sale (including sales of servicing rights) or similar transactions related to a transaction of the consumer (§716.14).

(D)   With the written consent or direction of the consumer (§6802).

(E)   To protect the confidentiality or security of the Credit Union’s records pertaining to the consumer, the service or product, or the transaction; to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability; for required institutional risk control, or for resolving customer disputes or inquires; to persons holding a legal or beneficial interest relating to the consumer; or, to the extent specifically permitted or required under other provisions of law and in accordance with the Right to Financial Privacy Act, to law enforcement agencies, self-regulatory organizations, or for an investigation on a matter related to public safety (§6802(e)).

(F)   To provide information to insurance rate advisory organizations, guaranty funds or agencies, applicable rating agencies of the Credit Union, persons assessing the Credit Union’s compliance with industry standards, and the institution’s attorneys, accounts, and auditors (§6802(e)).

(G)   To a credit reporting agency in accordance with FCRA (§6802(e)).

(H)   In connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of a business or operating unit if the disclosure of nonpublic personal information concerns solely consumers of such business or unit (§6802(e)).

(I)     To comply with Federal, State, or local laws, rules, and other applicable legal requirements, to comply with a properly authorized civil, criminal, or regulatory investigation or subpoena or summons by Federal, State or local authorities having jurisdiction over the financial institution for examination, compliance, or other purposes as authorized by law (§6802(e)).

(J)    Such financial records are disclosed (i) in response to an administrative subpoena; (ii) in response to a search warrant; (iii) in response to a judicial subpoena; or (iv) in response to a formal written request by a proper governmental authority  (§3402).

(5)   RESPONSIBILITY OF SERVICE PROVIDERS. The Credit Union only approves service providers with established policies of privacy similar to those of the Credit Union. The Credit Union requires contractual agreements from nonaffiliated third parties that will include confidentiality of member information disclosed by the Credit Union and prohibit the service provider from disclosure and reuse of nonpublic personal information for any reason other than the intended purpose.

(6)   CONFIDENTIALITY AND SECURITY SAFEGUARDS. The Credit Union maintains strict policies and security controls to assure that nonpublic personal information in the Credit Union’s computer systems and files is protected.

(A) Credit Union employees and certain contractors are permitted access to nonpublic personal information that they may need to perform their jobs and to provide service to the members.

(B)  Credit Union employees and contractors will have access to such nonpublic personal information only as necessary to conduct a transaction or respond to a member’s inquiries.

(C)  All Credit Union employees and contractors are required to respect member privacy through confidentiality and information security provisions included in the Credit Union’s employee policy manual and service agreements with the contractors.

(D)  No one except Credit Union employees and authorized contractors will have 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 member nonpublic personal information provided to the Credit Union and the information the Credit Union collects about the member. The Credit Union will continue to review its internal security controls to safeguard member nonpublic personal information as the Credit Union employs new technologies in the future.

(7) PRIVACY OF ELECTRONIC TRANSACTIONS.

(A)           Encryption. Electronic interfaces with members (such as Internet transactions) will be encrypted using Secure Socket Layer (SSL) 128-bit encryption.

(B)           Account Access. Member account information and transactions will be protected by a password that must be used in conjunction with a username or account number. Members must apply for this capability and be registered with the Credit Union for authentication purposes.

(C)           "Cookies". The Credit Union may use "cookies" as part of its web site interface. A "cookie" is a small file that is placed on the user's computer. While it contains no member information, it identifies the member's computer and allows the Credit Union to measure usage of the web site and customize the web site experience.

(D)           Links. The Credit Union will frequently link to other sites as a convenience to our members. The Credit Union will seek to link with other sites that adhere to similar privacy standards. However, the Credit Union is not responsible for the content of linked sites, or for their policies on the collection of member information.

(E)           Online Privacy of Children’s Information. The Credit Union will not collect, use or disclose online information received from children under age 13 without prior parental notification and consent, which will include an opportunity for the parent to prevent use of information and participation in the activity. Online information will only be used to respond directly to the child’s request and will not be used for other purposes without prior parental consent.

(i)             The Credit Union will not distribute to third parties, other than its affiliate, personally identifiable information without prior parental consent.

(ii)            The Credit Union will not post or otherwise distribute personally identifiable information without prior parental consent.

(iii)           The Credit Union will not entice by the prospect of a special game, prize or other activity, to divulge more information than is needed to participate in the activity.

(iv)           Parents/guardians may review personally identifiable information collected online from their children upon written request. The parent or guardian has the right to have information deleted and instruct the Credit Union to cease collecting further information from their child.

Protecting member privacy is an ongoing process and the Credit Union will continue to evaluate and review the measures taken to safeguard member information.

The Credit Union provides training to employees on how to recognize and control risk to nonpublic personal information, how to handle nonpublic personal information, and how to report unauthorized or fraudulent attempts to gain access to nonpublic personal information.

The Credit Union has controls and procedures whereby any new product, service, or delivery method shall be reviewed and modified to insure that it conforms to existing Credit Union privacy policies with regards to nonpublic personal information.

If nonpublic personal information is shared with vendors for business purposes all contracts and agreements between the vendors and the Credit Union will include a guarantee that the vendor will safeguard such information.

Because no policy can address every possible contingency and circumstance, Credit Union management shall use its good faith business judgment in administering this privacy policy and expects that all officers, volunteers, employees and members will use good faith in their actions to protect the privacy of Credit Union members.

The Credit Union reserves the right to amend this privacy policy in any respect with disclosure to members as required by law.

§ Section numbers refer to NCUA’s regulations, officially codified in the Code of Federal Regulation (CFR). 12 C.F.R. Parts 700-796