Trailhead Credit Union Privacy Policy

TRAILHEAD CREDIT UNION PRIVACY POLICY

Last Modified: December 10, 2017

This Privacy Policy describes the information that we gather from you, how we use and disclose your information, and the steps we take to protect your information. By using the Service, you consent to the privacy practices described in this Policy.

This Privacy Policy is incorporated into and is subject to the Terms of Use. Capitalized terms that are not defined in the Privacy Policy have the meaning given to them in the Terms of Use.

  1. INFORMATION WE COLLECT

 

 

User-provided Information: When you use the Service, you may provide and we may collect what is generally called “personally identifiable” information, such as your name and email address, mailing address, mobile phone number, and demographic information such as age, education, gender, interests and location. For example, you may provide us with personally identifiable information when you use the Service, or send us customer service related requests.

Device specific information and cookies: When you use the Service, we may collect your device’s device identifier, the IP address assigned to your computer or device and such location information as is provided to or can be inferred by us with respect to your device or computer. If the Service is being used though a social media site or application, we may receive information from that social media site or application about you based upon your settings with respect to sharing your information on that social media site or application. If the Service is being used though a computer browser, “cookies” may be used to collect and store data with respect to your utilization of the Service. If you set up your device, your computer browser or your social media applications to prevent us from accessing this information, you might not be able to use some or all of the features of our Service.

Aggregation of Financial Information: In order for you to benefit from the full functionality of our Service, our Service require access to your financial institution (“FI”) account data, including transaction history, balances, and account information. We may use a third party service provider to facilitate the collection of your FI account data from your FIs, including, but not limited to, accessing your FI account data, including financial transaction data, balances, and activity, and retrieving your FI account data from such third party financial institutions.

2. LIMITATIONS ON THE USE OF INFORMATION WE COLLECT

 

 

Your information is an integral part of our operation of the Service, and we use it in a variety of ways in providing the Service and operating our business. Our primary uses of the data you submit to us are responding to your requests and serving you better. Your personal data may be used in the following ways:

  • To operate, maintain, enhance, and provide you with the Service;
  • To personalize the features, performance, and support of the Service for your use;
  • To send you administrative notifications, such as security, support, or maintenance advisories;
  • To send you promotional/marketing information, newsletters, surveys, offers, or other information related to the Service and the activities of third parties we work with.
  • To provide you with opportunities and functionality that we think would be of particular interest to you;
  • To improve the quality of the Service;
  • To analyze, benchmark and conduct research on anonymized user data and user interactions with the Service.

3. HOW WE DISCLOSE YOUR INFORMATION

 

 

We do not sell your personally identifiable information to third parties, and we only share your personally identifiable information with third parties in the ways that are described in this Privacy Policy. We may disclose your personally identifiable information and other information we collect in some circumstances in connection with providing the Service and the operation of our business. For example:

  • We work with third party service providers to provide website, application development, hosting, maintenance, and other services for us. To the extent it is necessary for these third party service providers to complete their contractual obligations to us, these third parties may have access to or process your personally identifiable information. These disclosures are made under terms comparable to this Privacy Policy, and the recipients are limited to using the information the purpose for which it was provided. These companies are authorized to use your personally identifiable information only as necessary to provide these services to us.
  • We make certain automatically collected and other aggregate non-personally-identifiable information available to third parties, to: (i) comply with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.
  • With your explicit permission, we may make your personally identifiable information available to third parties: (i) for business or marketing purposes; or (ii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service. If, after providing your explicit permission, you decide you no longer want your personally identifiable information shared with third parties in this manner, you can opt out by contacting us at trailhead@abe.ai.
  • We may also disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity, as well as appropriate or necessary to take precautions against liability; to protect us and others from fraudulent, abusive, or unlawful uses or activity; to investigate and defend ourselves against any third party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Service; or to protect the rights, property, or personal safety of us, our users, or others.

4. COMMITMENT TO DATA SECURITY

 

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of your personally identifiable information. We have a data security policy in place that we regularly test. Our security policy utilizes encryption that meets standards applicable to processing and storage of financial data. and other security measures, such as SSL, to protect sensitive information (such as financial information, account data, including transaction history, balances, and account information) from hackers and unauthorized parties. If you choose to submit or access your personal information using the Service, we will implement reasonable security measures according to our security policy. We cannot, however, ensure or warrant the security of such information and you use the Service for such purposes at your own risk. We hereby DISCLAIM ANY EXPRESS OR IMPLIED WARRANTIES. YOU UTILIZE THE SERVICE AT YOUR OWN RISK AND ON AN “AS IS” BASIS. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Service if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

 

5. CHANGES AND UPDATES TO THIS PRIVACY POLICY

 

Please revisit this page periodically to stay abreast of any changes to this Privacy Policy, which may be revised periodically at our sole discretion, as provided in the Terms of Use. If we modify the Privacy Policy, we will make it available through the Service and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change prior to the change becoming effective. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made. Our amended Privacy Policy will automatically take effect after it is made available through the Service. If you do not agree with any changes to the Privacy Policy, you may stop using the Service. Your continued use of the Service after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the current version of the Privacy Policy.