Privacy and Disclosures
Last Updated: December 18, 2017
Android® and Google Play® are registered trademarks of Google, Inc. ("Google"). Facebook® is a registered trademark of Facebook, Inc. ("Facebook"). iPhone®, iPad®, iPod Touch® and the iTunes Store® are registered trademarks of Apple, Inc. ("Apple"). LinkedIn® is a registered trademark of LinkedIn Corporation ("LinkedIn"). Twitter® is a registered trademark of Twitter, Inc. ("Twitter"). Yelp® is a registered trademark of Yelp, Inc. ("Yelp"). Please be advised that Provident is not in any way affiliated with Apple, Facebook, Google, LinkedIn, Twitter or Yelp, nor are the Site/App Offerings or Provident Financial Products endorsed, administered or sponsored by any of the foregoing entities.
"Affiliates" shall mean companies related to Provident by common ownership or control. Affiliates include financial and non-financial companies. Currently, our Affiliates include Provident Plus Insurance Agency.
"Joint Marketing" shall mean a formal agreement between Provident and a Non-affiliated financial company whereby Provident and such Non-affiliated financial company market financial products or services to you. Our current Joint Marketing partners include both financial and non-financial companies.
"Non-affiliates" shall mean companies that are not related to Provident by common ownership or control. Non-affiliates include financial and non-financial companies.
YOUR CALIFORNIA PRIVACY RIGHTS
In accordance with California State law, we will not share information that we collect about California State residents with Non-affiliates except as permitted by law, such as with the consent of the applicable customer, to service the customer's account(s) or to fulfill rewards or other benefits. We will also limit the sharing of information about California State resident customers with our Affiliates to the extent required by applicable California State law.
In addition, if you are a resident of the State of California and would like to learn how your "personal information" (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information that we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please e-mail us at: email@example.com; call us at: (800) 632-4600; or send us mail to: 303 Twin Dolphin Drive, Redwood City, CA 94065.
Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please e-mail us at: firstname.lastname@example.org; send mail to: 303 Twin Dolphin Drive, Redwood City, CA 94065; or call us at: (800) 632-4600. Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.
VERMONT AND NORTH DAKOTA PRIVACY RIGHTS
In accordance with Vermont State law, we will not share information that we collect about Vermont State residents with Non-affiliates except as permitted by law, such as with the consent of the customer, to service the customer's account(s) or with other financial institutions with which we have Joint Marketing agreements. We will not share creditworthiness information about Vermont State residents with our Affiliates except with the authorization or consent of the applicable Vermont State residents.
For purposes of compliance with North Dakota Century Code §§ 6.08.1-01 to 6-08.1-08 and the Vermont Consumer Protection Act, 8 V.S.A. 10202, if you are a resident of the State of North Dakota or Vermont and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please visit www.providentcu.org/privacy. Please be advised that where North Dakota or Vermont State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with the law.
NEVADA PRIVACY RIGHTS
For purposes of complying with Nevada State law, if you prefer not to receive telemarketing calls or text messages from us, you may be placed on our internal Do Not Call List by calling us at: (800) 632-4600, or by writing us to: Provident Credit Union, 303 Twin Dolphin Drive, Redwood City, CA 94065. Nevada State law also requires that we provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Telephone Number: (702) 486-3132; E-mail: BCPINFO@ag.state.nv.us.
PERSONAL INFORMATION COLLECTED
USE OF PERSONAL INFORMATION
Subject to applicable state and federal law restrictions, by submitting your personal information by and through the Site/App Offerings, you agree that, within thirty (30) days of the date that you are provided a copy of the Privacy Notice, and even if you are no longer a customer of Provident, unless you opt-out (see the last sentence of this paragraph), we may share, or otherwise provide that personal information (other than Sensitive Information) to: (a) Affiliates; (b) Non-affiliates; (c) and other third-parties for marketing purposes, including the marketing of Provident products and/or services, the marketing of products and/or services of Affiliates and Non-affiliates and in connection with Joint Marketing campaigns undertaken by Provident and other financial services providers. Some of the entities that we may share your personal information with as set forth in the preceding sentence may include, but are not limited to: (i) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (ii) e-mail marketers; (iii) telemarketers and SMS text message marketers (where permitted by applicable law); and (iv) direct marketers. Please note that if you wish to prevent the sharing of your personal information with Non-affiliated third-parties for marketing purposes and/or you wish stop receiving future communications from us and/or third-parties, please call us at (800) 632-4600, or see the "Opt-Out/Unsubscribe" section below.
Where you submit personal information, we use the personal information that you make available to personalize your experience with the Site and/or App, to facilitate the delivery of the applicable Site/App Offerings to you, including to respond to any inquiries made by you, and to meet our everyday business needs which may include processing your Provident Financial Product and/or account transactions, maintaining your Provident Financial Product account(s) and/or reporting to credit bureaus.
You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Site/App Offerings, and to keep you informed of our other products and services.
In connection with the foregoing, we may employ other companies and individuals to perform certain functions on our behalf. Examples include companies that perform support services for us such as data processors, technical systems consultants and programmers, check printers, companies that send direct and electronic mail, remove duplicate information from end-user lists, analyze data and provide marketing analysis. The agents performing these limited functions on our behalf shall have access to our end-users' personal information as needed to perform these functions for us, but we do not permit them to use end-user personal information for other purposes.
We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience with the Site/App Offerings and/or to contact you when necessary in connection with your use of the Site/App Offerings. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Site/App Offerings. We may also combine the information we have gathered about you with information from other sources.
By submitting your personal information by and through the Site/App Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR Â§310 et seq.), as amended from time to time (the "Rule") and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission's Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.
We reserve the right to release current or past personal information, including Sensitive Information: (x) in the event that we believe that the Site/App Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (y) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; or (z) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Provident is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site and App of any change in ownership or uses of your personal information, as well as any choices that you may have regarding opting-out of the sharing of your personal information.
You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with third-parties for suppression purposes in compliance with applicable law, including the CAN-SPAM Act of 2003, as amended from time to time. End-users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third parties without permission.
NON-PERSONAL INFORMATION COLLECTION AND USE
Computer IP Addresses/Browser Type
We may collect certain non-personally identifiable information about you and your desktop computer when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Site/App Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Site/App Offerings.
Provident records and retains online transactions that users perform through the Site and/or App, such as those performed within online banking, online loan applications and/or account opening. This is necessary in order to conduct business and satisfy record-keeping requirements. Information about what pages have been viewed, for how long and the paths people take through the Site and/or App is also collected in order to evaluate how the Site Offerings are being used, so that Provident can make improvements. Mostly this "tracking" information is anonymous and viewed in aggregate, but there are also areas of the Site and/or App where users are personally identified via a secure sign on, and we retain the information for a limited time in order to help protect Provident and its members from actual or potential fraud, and to be able to assist members who need help. No personally identifying tracking information is shared outside of Provident, except when necessary for law enforcement purposes.
Some of this information collection in the preceding paragraph is accomplished via "cookies" (also known as "http cookies"). Cookies are small bits of data that a web page can use to assign an anonymous, unique identifier to the applicable end-user's computer and/or Mobile Device, as applicable. To find out more about cookies, please visit www.cookiecentral.com.
Mobile Device Information
We may collect certain non-personally identifiable information about you and your Mobile Device when you access the App and/or visit certain App pages. This non-personally identifiable information includes, without limitation, the following information pertaining to your Mobile Device and your use of the App: (a) Mobile Device platform type; (b) Mobile Device identifier; (c) SDK version; (d) API key (identifier for the App); (e) App version; (f) iOS Identifier for Advertising (if applicable); (g) iOS Identifier for Vendors (if applicable); (h) Media Access Control (MAC) address; (i) International Mobile Equipment Identity (IMEI); (j) the model type, manufacture and iOS version of the Mobile Device; (k) your App session start/stop time and date; and (l) the actions taken while utilizing the App. We use the non-personally identifiable information identified in this paragraph to improve the design and content of the Site/App Offerings and to enable us to personalize your App experience. We also may use this information in the aggregate to analyze Site/App Offerings usage, alter existing Site/App Offerings and/or develop new or different Site/App Offerings.
Please be advised that, with your permission, Provident uses geolocation tracking technology ("Location Services") in order to enable certain features of the App, such as providing you with information regarding your proximity to the nearest Provident branch. In connection with the foregoing, your geolocation information will not be shared with third parties for marketing purposes. Other than as set forth in this paragraph, Provident does not track your geolocation, or share or use your geolocation information, for any purpose.
Cross Device Tracking
Provident tracks end-users' use of the Site/App Offerings across various devices, including your personal computer and Mobile Device, in order to optimize and personalize your Site/App Offerings experience. Provident may collect certain of your personal information across various devices.
Behavioral Tracking and Advertising
Online behavioral tracking and advertising ("OBA") refers to the practice of collecting information from a computer or Mobile Device of a visitor to our Site and/or App, including certain web-browsing activities of that visitor across non-affiliated websites over time, in order to deliver advertisements that may be of interest to that visitor based on their browsing history. Through OBA, we hope to deliver advertisements that are most likely to be of interest to you using information about your other web-browsing activities (e.g., the web pages you visit, search terms you enter, and the way you move through our online services on your computer or device) or your personal profile (e.g., demographic or location information). Certain companies we work with may set cookies and use related tracking technologies, such as the clear GIFs discussed above, throughout our online services or in our communications to support these OBA efforts. If you do not want your information collected and used by the companies that we work with for OBA purposes, you can opt out of this form of OBA by following the instructions in the next paragraph.
There are two (2) ways that you can opt out of OBA from certain Provident ads on third-party websites. One way is through the cross-industry Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance ("DAA"). To opt out of OBA, please click on the following link and follow the instructions: youradchoices.com. Another way to opt out of OBA is by clicking on the Advertising Options Icon featured on certain Provident ads on third-party websites. When clicked, the icon: (a) describes the collection and uses of data gathered at the relevant third-party website; and (b) provides a way for you to opt out of data collection and use by the third parties listed for the purposes of OBA. Users may also be able to disable some, but not all, of this tracking activity by utilizing the "Do Not Track" setting or similar options within most major Internet browsers. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third parties in connection with the Site and App.
Provident reserves the right to transfer and/or sell aggregate or group data about end-users of the Site/App Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Site/App Offerings users as a group, without disclosing personally identifiable information.
SOCIAL MEDIA WEBSITES
If you engage in any interaction with Provident, other end-users or any third-party on any Social Media Pages, you should be aware that: (a) the personal information that you submit by and through such Social Media Pages can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where Provident responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all members/users of Provident's social media accounts.
We are not responsible for the personal information that you choose to submit on any Social Media Websites. The Social Media Websites operate independently from Provident, and we are not responsible for such Social Media Websites' interfaces or privacy or security practices. We encourage you to review the privacy policies and settings of the Social Media Websites with which you interact to help you understand those Social Media Websites' privacy practices. If you have questions about the security and privacy settings of any Social Media Websites that you use, please refer to their applicable privacy notices or policies.
This Site and/or App may contain links to third-party owned and/or operated websites including, without limitation, the Social Media Websites. Provident is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Provident has no responsibility or liability relating to them.
For more information about our security measures, please visit the Security & Fraud pages of the Site and App.
We endeavor to safeguard and protect our end-users' personal information. When end-users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where we ask end-users to enter Sensitive Information, if ever, and when we store and transmit such Sensitive Information, that information is encrypted with advanced TLS (Transport Layer Security).
Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All of our end-users' personal information is restricted in our offices, as well as the offices of our third-party service providers. Only employees or third-party agents who need end-user personal information to perform a specific job are granted access to end-user personal information. Our employees are dedicated to ensuring the security and privacy of all end-user personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store end-user personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.
Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site, App, other Site/App Offerings or otherwise via the Internet or wireless networks, is done at your own risk.
In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
Visitors under thirteen (13) years of age are not permitted to use and/or submit their personal information at the Site and/or through the App. Provident does not knowingly solicit or collect information from visitors under thirteen (13) years of age. Provident encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
To opt-out of sharing your information with Non-affiliated third-parties for marketing purposes, please call us at: (800) 632-4600. To opt-out of receiving e-mail and other forms of communication from us, you can call us at: (800) 632-4600 or follow the instructions included in the privacy notice mailing or other communication. If you wish to opt out of receiving e-mail and other forms of communication from a third-party, whether an Affiliate, Non-affiliate or Joint Marketing partner, please consult that third-party's opt out policies or contact that third-party directly.
Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Site/App Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Site/App Offerings-related and/or inquiry response-related messages from Provident, you must cease requesting and/or utilizing the Site/App Offerings and/or cease submitting inquiries to Provident, as applicable.
DELETING, MODIFYING AND UPDATING YOUR INFORMATION
At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by calling (800)632-4600, visiting a Provident Community Branch, or within online banking. We ask individual end-users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
Please be advised that deleting your personal information may terminate your access to certain of the Site/App Offerings. If you wish to continue using the full complement of Site/App Offerings, you may not be able to delete all of the personal information that we have on file for you.
Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
TRANSFER OF PERSONAL INFORMATION INTERNATIONALLY
FILING A COMPLAINT WITH THE FEDERAL TRADE COMMISSION
To file a complaint regarding our privacy practices, click here.