Communications Family Credit Union Privacy Policy

Communications Family Credit Union is committed to provide quality services and products to meet the financial needs of our members. We deliver our services to all members, regardless of location, which translates into the use of the newest technologies for service delivery. A logical concern arising from the rapidly changing world of technology, specifically the Internet, is your right to conduct business with us in confidence, and your right to maintain privacy over your financial matters.

We want to assure you that we share your privacy concerns. Communications Family Credit Union adheres to strict confidentiality and privacy practices covering all member transactions and information.

To this end, Communications Family Credit Union has adopted a Confidentiality of Member Information Policy. This policy is distributed to all credit union staff. The policy basically states that any information disclosed by you to Communications Family Credit Union in the course of normal business will be held in the strictest confidence. Unauthorized or illegal disclosure of your private information is considered a policy violation and subjects the guilty party to discipline. Employees are reminded that their responsibility to maintain this privacy continues even after their employment ends with Communications Family Credit Union.

In the course of conducting routine business transactions, Communications Family Credit Union gathers certain information about you. This information could be collected from applications you submit to us or from other providers of information to which we subscribe (credit bureaus, etc). In some cases, we need to share that information with other institutions in order to complete your transaction. For example, when you apply for a loan we submit certain information to credit bureaus in order to obtain a recent credit rating about you. This information is reviewed and is crucial in completing the loan for which you applied. This type of information sharing is conducted in order for you to complete normal financial business transactions with us. We still treat this information as confidential. Any personal information that you provide to us, or we gather about you, is kept private.

To fulfill our commitment to you and your financial privacy we have adopted the following policy and procedures:

INFORMATION WE COLLECT

We collect and use only the personal information necessary to complete your transactions. We collect nonpublic personal information about you from some or all of the following sources:

• Information we receive from you on applications and other forms;
• Information about your transactions with us, our affiliates, or others;
• Information we receive from a consumer reporting agency;
• Information obtained when verifying the information you provide on an application or other forms, such as from your current or past employers or from other institutions where you conduct financial transactions.

INFORMATION WE DISCLOSE

• We will share your information only when necessary. We will only share information to support the products and services we provide, when we are required to do so by the government or a court order, or when we partner with other companies to offer a product or service.
• We may disclose information we collect about you under circumstances as permitted or required by law. These disclosures typically include information to process transactions on your behalf, conduct the operations of our credit union, follow your instructions as you authorize, or protect the security of our financial records.
• We are committed to providing you with competitive products and services to meet your financial needs, which necessitates we share information about you with our affiliates, to complete your transactions, and to provide you with certain financial opportunities. We have also entered into agreements with other companies that provide either services to us or additional financial products for you to consider.
• Of the information collected, we will disclose only that which is necessary to conduct the business at hand to companies that perform marketing services on our behalf or to other companies we utilize to support the products and services we offer. We may also disclose information about you under other circumstances as permitted by law.

OUR SECURITY MEASURES

• We have adopted security measures to ensure the safety of your personal information. We are subject to regular governmental and professional audits of our security procedures and policies. The audits ensure our security measures are adhered to and operate as intended.
• We partner only with entities that follow strict information confidentiality procedures. Those businesses must also demonstrate a commitment to security of information by way of contractual commitments with us. There are no cases where any of these business partners are authorized to charge a fee to our members without his or her consent. We do not sell our member information to any telemarketing or other third party firm for their own use.
• We do not share non-public personal information about non-members who may use some of our services, such as our ATM machines.
• We do not share non-public personal information about those persons who are no longer our members, except where required by law.
• Although we may store these records for a period of time, we do not share information contained on applications or other documents about those persons for whom membership or other services were denied or credit not extended, except where required by law.
• We restrict access to nonpublic personal information about you to those employees who have a specific business purpose in utilizing your data. Our employees, members of the Board of Directors and Committee Members shall maintain confidentiality and member privacy. We maintain physical, electronic, and procedural safeguards that comply with federal regulations and industry practices to safeguard your nonpublic personal information.

OPT-OUT OPTION

At this time, Communications Family Credit Union does not engage in activities that qualify for an "opt-out" option under the federal regulation.

However, if you wish to be excluded from marketing offers from us or our affiliates, you may contact us to be excluded from future offerings.

ON-LINE PRIVACY MEASURES

Visiting Us Online

We may gather information about which sites our visitors browse. This enables us to track how a visitor navigates through the site areas in which they show interest. We gather information such as number of hits to the site, page visits, and length of user sessions. This is similar to a traffic report: it tracks trends and behaviors of members/users in general, but does not identify individuals in particular. We use this information to better serve you and it helps keep our site relevant and useful.

Links to Other Web Sites

Links from our website are provided for your convenience only. These linked sites are separate from our credit union's web site. We are not responsible for the content or availability of any linked third party websites or the privacy practices of such third parties. In addition, a link from our website to another does not indicate that Communications Family Credit Union endorses the services or policies of such third party websites. You should always investigate the information practices of all websites that you access and carefully examine the privacy policies of any websites linking to or from our website. Information collected from the linked websites will be subject to the information practices of those websites.

Online Privacy

Our privacy policy is the same whether you are online or not. At our website, you may apply for membership, accounts, loans and services. You may also communicate with us via the secure "Contact Us" form and secure "Chat". To protect information you provide us online, multiple levels of security are utilized. All applications, forms and World Wide Branchsm transactions are submitted securely using the industry standard "Secure Socket Layer" (SSL) encryption to secure your submission. 128-bit encryption and firewalls are used to secure your information. A firewall is a security measure that insulates the computer network from the World Wide Web. Traffic coming in and out of the firewall is analyzed, which could indicate intrusion activity and computer viruses. Communications Family Credit Union contracts with a third-party technology specialist to try to penetrate our network and assess and evaluate our security. Communications Family Credit Union contracts with a third party to host our website, World Wide Branchsm Internet home banking, and the live chat product. These companies are required to ensure their systems meet acceptable levels of security.

Our Use of Cookies

If you conduct transactions with Communications Family Credit Union via World Wide Branch^sm, you may notice the use of Internet cookies. Cookies are a small text file assigned and attached by a web server to the directory file on your computer. Cookies enable our systems to recognize your browser and your information as you navigate and conduct transactions within World Wide Branch^sm. If we did not use cookies within World Wide Branch^sm, you would need to enter your account number and password each time you wanted to see another page or each transaction you initiate. World Wide Branch^sm uses temporary session cookies that are stored on your computer only during your current session and are automatically deleted from your computer when you close your browser. Information may be collected from your computer, such as browser type and version, operating system, and the internet service provider you use to enforce an effective authentication system that is compliant with FFIEC requirements that will safeguard member information.

Protecting Children's Online Privacy

Communications Family Credit Union does not knowingly collect, nor is our web site designed or directed to use personal information from children under the age of 13 without containing verifiable consent from their parents. We do offer a "Kids" section on our web site that children can access external links to other sites that are age-appropriate. Should a child choose to submit information or questions to us, we would only use that information to respond directly to that child, seek parental consent or provide parental notice. No information would be stored.

WHAT YOU AS A MEMBER CAN DO TO HELP

Communications Family Credit Union is committed to protecting the privacy of our members. Members can help by following some simple suggestions:

• Protect your account numbers, plastic card numbers, (Personal Identification Number) PINs and passwords. Never keep your PIN with your card.
• Use caution when disclosing your account numbers, Social Security numbers, etc. to other persons. If you receive a phone call from someone claiming to be from the credit union, and that unknown person asks for account numbers or other identifying information, do not give that information. Communications Family Credit Union staff will have access to your information and will not need to ask for it.
• Keep your information with us current. If your address or phone number changes, please let us know promptly. It is important that we have current information as to how to reach you. If we detect potential fraudulent or unauthorized activity or use of your account, we will attempt to contact you immediately.
• After you complete your online session, log-off before surfing other sites or by turning off your PC. It is suggested that you do not surf other sites during your online banking session. As this could allow a cookie to be attached and possibly compromise your information.
• Review your account statements as soon as possible after receiving them. Contact us immediately of any discrepancies.

Let us know if you have any questions concerning this notice or your account or any services we provide. Please do not hesitate to contact us. We are here to serve you!

You may contact us at any office of Communications Family Credit Union or by calling us at 1-800-227-2328, or (989) 249-8200.