Last updated: January 23, 2019
ROYAL CU ONLINE PRIVACY NOTICE
Information Collected by ROYAL CU
- If you use ROYAL CU’s websites, mobile applications, or other services, ROYAL CU may collect information about you, including your personal information, information from your mobile device, information about your communications with ROYAL CU team members and other information.
- We may collect information from a variety of sources, including from you directly, from your use of the ROYAL CU financial services, from your communications with ROYAL CU team members, and from third party sources.
- See Section II (below)
How ROYAL CU Uses and Shares Collected Information
- We may use information we collect from you to provide you with financial services, to provide you with member service, to communicate with you about your account, to offer you products or services, and for other purposes.
- We may share certain information we collect from you (including personal information) with third parties acting on our behalf (including third party payment card processors), with other financial companies for joint marketing purposes, with credit bureaus, and with other third parties.
- We may share aggregated data (which excludes your personal information) with our business partners and other third parties.
- See Section III (below)
Correcting Personal Information and Opting Out
- You may review and update certain personal information by signing in to your account, by contacting us, or by making the request in person at any of our ROYAL CU locations.
- See Section IV (below)
- You may opt out of receiving certain communications from ROYAL CU, such as communications regarding marketing or promotions, by clicking on the email opt out link.
- See Section V (below)
Safeguarding Your Information
- ROYAL CU is committed to maintaining the security of the data you provide us. However, please note that there is always some risk in transmitting information over the Internet. To learn more about our security practices, visit the Security and Fraud page on the ROYAL CU website.
- See Section VI (below)
Your California Privacy Rights
- California residents have the right to request and receive certain information about our disclosure of personal information to third parties for their own direct marketing purposes. However, because we will not share your personal information with our joint marketing partners without first giving you additional privacy choices, we are exempt from having to meet this requirement.
- See Section VII (below)
Tracking and Analytics
- The ROYAL CU websites currently do not respond to “Do Not Track” signals from browsers.
- We work with third-party analytics service providers, including but not limited to Google Ads and Twitter Ads, to help us better understand how you use ROYAL CU websites.
- Third parties may collect certain information on third-party websites where ROYAL CU advertises; however, we do not allow third parties to collect our users’ personal information on our websites or through our online services.
- See Section VIII (below)
- This Privacy Notice does not apply to websites owned by other companies.
- We do not seek to collect, nor do we knowingly collect information from children under 13.
- If you are located outside of the United States and are using the financial services, you consent to our transfer, processing, and storage of your information in the United States.
- See Section IX (below)
- You may contact us by calling 800.341.9911 or by logging in to Online Banking and sending us a Secure Message.
- See Section X (below)
Updates to Privacy Notice
- If we update this Privacy Notice, we will note at the top of this page the date that any changes are made or become effective.
- Your inaction or continued use of the financial services, including access to the ROYAL CU websites, after any such updates or notices will tell us that you agree to these changes.
- See Section XI (below)
Royal Credit Union (“ROYAL CU” or “we”) is a not-for-profit credit union. We are committed to respecting and protecting the privacy of our online visitors and Members. We recognize that individuals need to understand how their privacy is protected, so we have established the following privacy notice (“Privacy Notice”) for our users.
This Privacy Notice explains what personal information ROYAL CU will collect about you from our ROYAL CU websites and ROYAL CU mobile applications, both as defined below (collectively, the “online services”) as well as from third-party and offline sources. This Privacy Notice also explains how we use, protect, and disclose information to provide you with the online services and other financial services (collectively, the “financial services”).
Do you have a financial account with ROYAL CU? (In other words, you are a member.) We use and share your personal information in accordance with the ROYAL CU U.S. Consumer Privacy Notice.
What does personal information mean? “Personal information” means personally identifiable information, such as your name, email address, telephone number, and account numbers. It does not include aggregated data that does not reveal your identity or anything about you individually. Rather, aggregated data consists of information about a group that includes you. Remember, aggregated data is not considered personal information.
What do ROYAL CU websites refer to? These are ROYAL CU’s websites that link to this Privacy Notice, including but not limited to rcu.org.
What do ROYAL CU mobile applications (apps) include? These are ROYAL CU’s mobile apps that are available for your mobile device (e.g., phone or tablet), including ROYAL CU’s mobile app that allows members to manage their account.
II. INFORMATION COLLECTED BY ROYAL CU
Why does ROYAL CU collect personal information? We collect personal information because this information makes it possible for us to provide you with the full benefits of our financial services. ROYAL CU collects certain information from you, your devices, the applications you use to access our financial services, and from third-party sources so that we can provide these services to you
1. INFORMATION THAT YOU PROVIDE TO ROYAL CU
You may provide personal information directly to ROYAL CU both online and offline for different reasons. This information includes, but is not limited to, your name, address, email address, and phone number. You may also provide personal information to ROYAL CU online when you complete an online form on a ROYAL CU website, pay a bill online, or subscribe to electronic communications from ROYAL CU.
Other ways you may provide personal information are when you provide feedback to us through the ROYAL CU websites, respond to surveys and questionnaires that we send you, provide information to ROYAL CU team members, or provide personal information to us through other online means.
What’s more, you may provide personal information offline to ROYAL CU when you complete membership or credit applications (e.g., to open a ROYAL CU account or apply for a loan), provide information to ROYAL CU team members, deposit money, use your debit card, or provide personal information to us through other offline means.
When you sign up for or maintain a financial account with ROYAL CU, you may provide the types of personal information described in the U.S. Consumer Privacy Notice, including but not limited to your Social Security number and employment information.
2. INFORMATION AUTOMATICALLY COLLECTED BY ROYAL CU
In addition to the information you provide, when you use our online services, we may also automatically collect the following types of information from your devices and applications that you use.
- ROYAL CU Mobile Applications: If you choose to use a ROYAL CU mobile app, we may collect certain information from the app and your mobile device (“mobile app data”), including but not limited to geographic location information, unique device identifier information, and website data (as defined above). If the ROYAL CU mobile app collects any sensitive information from your mobile device that is not identified here, then we will notify you before doing so.
3. INFORMATION COLLECTED FROM THIRD PARTY SOURCES
In addition to personal information that you provide to ROYAL CU, we may also collect information about you, including personal information, from third-party sources, including but not limited to credit reports from consumer reporting agencies and information from propensity information sellers (“third-party data”). This includes, but is not limited to instances in which you affirmatively authorize third parties to provide us with information. Third-party data includes both personal information and information that is not personally identifiable to you.
When you sign up for an account with ROYAL CU, we may also collect information about you, including personal information, from third-party sources as described in the U.S. Consumer Privacy Notice, including, but not limited to your credit history, payment history, and account balances.
4. INFORMATION COLLECTED FROM ONLINE TOOLS
We may feature certain tools through our online services, such as online calculators (“online tools”). These online tools do not require you to log in or enter your contact information to use the online tool. The information you provide when using these online tools is not associated with you or your account and, for purposes of this Privacy Notice, is not considered to be personal information.
III. USE AND SHARING OF COLLECTED INFORMATION
1. COLLECTED INFORMATION
ROYAL CU may use your personal information, third-party data, mobile app data, website data, and forum postings to:
- Provide you with services or other products, financial services, and information that you have requested or in connection with our financial services;
- Maintain your account;
- Allow you to apply for products or services and process your applications and transactions;
- Manage our business, including performing accounting, auditing, and other internal functions;
- Verify your identity and authenticate you (such as when you request access to your account information);
- Communicate with you about your account, in response to your requests, to notify you about important information regarding financial services, and to provide you with other administrative information;
- Communicate with you about special offers, ads, events, or new products or services that may be of interest to you;
- Evaluate and improve our websites and other offerings;
- Provide you with member service;
- Personalize and tailor our services and otherwise enhance the member experience;
- Conduct research and perform analysis in order to measure, maintain, protect, develop, and improve our products and services;
- Use in the case of risk control, fraud detection, and prevention;
- Comply with laws and regulations, contractual obligations, and our own internal policies; and
- Use for other purposes as permitted by applicable law.
ROYAL CU may share or disclose collected information (including personal information) in the following situations:
- With third parties acting on our behalf, such as third party payment card processors, call-center operators, shippers, servicers, marketing providers, people who analyze data for us, and other service providers;
- With other financial companies for joint marketing purposes (e.g., to bring you co-branded services or products);
- If ROYAL CU is involved in any merger, acquisition, sale of company assets, transition of service to another provider, or insolvency, bankruptcy, or receivership, ROYAL CU reserves the right to transfer your collected information (including personal information) in connection with such transaction;
- If we believe such disclosure is necessary to identify, contract, or bring legal action regarding injury or interference with the rights and property of ROYAL CU, including to enforce our rights against unauthorized access or attempted unauthorized access to our information technology assets or against other inappropriate use of our financial services;
- To report to credit bureaus;
- To comply with laws, regulations, court orders, and subpoenas or similar requests for information by authorities, or as otherwise required by law;
- To respond to an emergency;
- To protect the rights, property, safety, and security of members and others; and
- To assist us in preventing or investigating fraud, security, technical issues, or to otherwise manage risks.
If you are a ROYAL CU member, we may use and share your personal information as described in the U.S. Consumer Privacy Notice. The U.S. Consumer Privacy Notice also provides information about how you may limit certain types of sharing.
ROYAL CU does not share your personal information with nonaffiliated third parties for their own marketing purposes.
2. AGGREGATED DATA
ROYAL CU may aggregate collected information gathered from our various users (so that it no longer identifies you specifically) and share it with ROYAL CU’s business partners and other third parties.
ROYAL CU may also store such aggregated data for a reasonable period of time after you terminate your account(s) or stop using our financial services.
The aggregated data may also be used by ROYAL CU or third parties for research purposes (including to help ROYAL CU improve its products). This, among other uses, allows companies to develop better products for ROYAL CU’s users.
3. WEBSITE DATA
In addition to the uses described above, ROYAL CU may use website data to improve our financial services, as well as help us understand how members are using our financial services. This information is also collected for statistical analysis, to determine what information is of most and least interest to our members, to improve the usefulness of the financial services, and finally, for other purposes described in this Privacy Notice. ROYAL CU may share website data with our business partners and other third parties (including for the reasons listed above).
IV. REVIEW AND CORRECTION OF PERSONAL INFORMATION
You may review, correct, and update certain personal information (such as your name and contact information) by signing in to your account on the ROYAL CU website or the ROYAL CU mobile app and editing the information listed in your account profile.
You may also correct or update your personal information by contacting us via the Contact Us section below or by making the request in person at any of our ROYAL CU locations.
V. OPTING OUT
You may occasionally receive emails from ROYAL CU, including emails about products or services, marketing or promotions, research, and/or other topics. To contact you, ROYAL CU may use the information you provide to us, including email, direct (postal) mail, or phone. You may, at any time, inform us that you do not want ROYAL CU to contact you with marketing or promotional communications by sending your request via the Contact Us section below.
Do you wish to opt out of ROYAL CU’s promotional emails? Simply click on the email opt out link. After you opt out of marketing and promotional messages, you’ll still receive other transactional messages, such as notifications and information relating to your account and services. If you also wish to opt out of these transactional email notifications, simply unsubscribe using the opt out link.
Do you want to opt out of receiving emails? Contact Us
VI. SAFEGUARDING YOUR INFORMATION
ROYAL CU is committed to maintaining the security of the data you provide us. We use security controls that comply with applicable federal laws to protect against unauthorized access and use of your personal information that’s in our custody or control. Safety measures may include computer safeguards, secured files, and buildings. To learn more about our security practices, visit the Security and Fraud page on the ROYAL CU website.
While we are focused on the security of your Personal Information, you must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others. For this reason, ROYAL CU cannot promise, and you should not expect, that we will be able to protect your Personal Information at all times and in all circumstances. ROYAL CU cannot guarantee the security and privacy of transmissions via the Internet, and we will not be liable for any lack of security relating to the use of the Banking Services by you. You agree that you will not hold ROYAL CU liable for any damages resulting from any loss of privacy or security occurring in connection with any such communications.
VII. CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS
Are you a California resident? Under California law, you may have the right to request and receive certain information about our disclosure of your personal information to third parties for their direct marketing purposes, and your choices with respect to such disclosures. However, because we will not share your personal information with our joint marketing partners without first giving you additional privacy choices, we are exempt from having to meet this requirement.
VIII. TRACKING; THIRD-PARTY ANALYTICS PROVIDERS; ADVERTISING
1. DO NOT TRACK DISCLOSURE
Certain web browsers may provide a do-not-track (“DNT”) option. You may be able to ask your browser to inform websites that you do not wish your activities to be tracked, either with cookies or other persistent identifiers, commonly called “DNT signals.” Because there is not yet a common understanding of how to interpret web browser-based DNT signals other than cookies, our websites do not currently respond to DNT signals.
2. THIRD-PARTY ANALYTICS PROVIDERS
We work with third-party analytics providers, including but not limited to Google Analytics and Google Adwords, to help us better understand how you use ROYAL CU websites.
For example, we use Google Analytics to learn more about the types of users that visit the ROYAL CU websites and to help improve the ROYAL CU websites. Google Analytics provides us with certain data regarding the demographics of the users that visit the ROYAL CU websites.
To provide this service, Google Analytics may collect certain information about you from your computer, including but not limited to:
- information regarding your visit (such as the pages you visit and the length of your visit)
- information about your device (such as your IP address)
- how you got to the website, and other information about you.
You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: google.com/policies/privacy/partners/.
You can opt-out of Google Analytics by using the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout/.
Other ways you can opt out of other website data tracking include:
- accessing the ROYAL CU websites via the private browsing function on your browser
- clearing the cookies on your browser on a regular basis, and
- going to https://adssettings.google.com to set your preferences on Google tracking.
Third parties may collect certain information on third-party websites where ROYAL CU advertises; however, we do not allow third parties to collect our users’ personal information on our websites or through our online services.
The ROYAL CU websites and ROYAL CU mobile app may contain links to websites owned by other companies. ROYAL CU is not responsible for the content or privacy practices of websites owned by other companies. We recommend that you carefully review the privacy notice for each of the websites you visit because ROYAL CU has no control over the privacy practices or content of these linked sites.
ROYAL CU websites and the ROYAL CU mobile app are intended for use within the U.S. (unless otherwise specified). This includes any information you provide using either our websites or our mobile app.
Accordingly, if you do not reside in the U.S. and are using ROYAL CU online services, any personal information you provide to us may be transferred to and processed on computers in the U.S. and other countries.
The data protection and privacy laws of other countries, including the U.S., may not afford you the same level of protection as those in your own country. Do not provide your personal information to us if you do not want this information to be transferred outside of your country, or if the laws in your country restrict these types of transfers. We will handle the personal information you provide in accordance with this Privacy Notice.
By doing business or interacting with ROYAL CU, using our financial services, or by otherwise providing us with your personal information, you agree to the terms of this Privacy Notice and consent to the transfer, storage, and processing of your personal information to and within facilities located in the U.S. and other facility locations selected by ROYAL CU.
This Privacy Notice addresses our procedures for handling the personal information of members in the United States who are at least 13 years old. We do not seek to, nor do we knowingly collect, information from children under 13 years old.
X. CONTACT US
Do you have questions about our Privacy Notice? We love chatting with our members! Ask us questions about this Privacy Notice if there’s something you don’t understand.
Do you need to update your information? It’s very important to keep your account information up to date. Some of your account information can be changed online, but you can also request changes in other ways.
To update your information online, go to the Self Service section in Online Banking.
To update or change any of your information in person, visit one of our neighborhood financial center locations or contact us in one of the following ways:
By Postal Mail:
P.O. Box 970
Eau Claire, WI 54701
Log in to Online Banking and send us a Secure Message.
XI. UPDATES TO PRIVACY NOTICE; CONSENT
Each time you use our financial services, you are indicating you acknowledge and consent to the collection, use, and disclosure of your personal information as set forth in this Privacy Notice.
From time to time, we may update this Privacy Notice. If we do, we will note the date that any changes are made and/or when they become effective (which you can find at the top of this page).
If the changes being made are material (that is, we make a major change in the important points of this Privacy Notice), we may notify you of the changes in a more prominent way, such as through an email. Your inaction or continued use of our financial services after the revised Privacy Notice is posted or after any such notices are sent will tell us that you agree to these changes. If you do not accept the terms outlined in this Privacy Notice or the revised Privacy Notice, please do not provide us with personal information or use our financial services.