CU Direct Corporation: Privacy Policy and Notice


This Privacy Policy and Notice is effective as of April 1, 2019.


OUR COMMITEMENT TO YOUR PRIVACY


This Privacy Policy and Notice (“Privacy Policy”) describes:

  • How and why we collect certain information from you via our Services;
  • How we use and with whom we share this information;
  • How you can access and update this information
  • The choices you can make about how we collect, use and share your information; and
  • How we safeguard your information.

CU Direct Corporation and its affiliates (“CUDC”) is a third-party service provider to certain financial institutions, and our goal is to protect the privacy of our clients, and their customers. This Privacy Policy is in effect for information we collect and/or own through our website, online services, third party providers, or applications submitted by our customers (collectively, “Information Channels”). This Privacy Policy may be updated or modified at any time and shall become effective once the Privacy Policy is made available for viewing.


CONTACT US


If you have any questions regarding this Privacy Policy or our information collection and use practices, please contact us at privacy@cudirect.com, OR 1-877-744-2835 and follow the telephone prompts OR by mail at CU Direct Corporation, 18400 Von Karman, Suite 900, Irvine, CA 92612, Attn: PRIVACY.


SAFEGUARDS


CUDC maintains industry safeguards, in accordance with applicable federal and state laws and regulations, to keep your Personal Information safe and secure. When we provide Personal Information to Financial Entities, our affiliates, or third-party service providers, we require that these parties agree to process and keep the information in compliance with applicable privacy laws. The use of your information by our business partners may be subject to that party’s own privacy notice. Unless we are permitted by law, we will not disclose the information we collect about you from consumer or credit reporting agencies, without your consent. For certain online features or services, such as those that that may include Personal Information, we require the use of username/password and/or encryption technologies for the protection of your Personal Information. You are responsible for protecting your username, password, and other user account information from disclosure to third parties, and you are restricted from circumventing the use of required encryption technologies. You agree to: (a) immediately notify us at privacy@cudirect.com of any unauthorized use of your username, password, and/or user account information, and/or any other breach of security; and (b) make sure that you log out from your user account at the end of each session. While we may provide certain safeguards to protect your confidential information, we do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error.


YOUR CONSENT TO THIS PRIVACY NOTICE


You consent to the collection and use of your information by CUDC in compliance with this Privacy Policy by your submitting Personal Information to CUDC, or using our services, unless you inform us otherwise, as allowable by law. Your available information choices are set forth below.


TYPES OF INFORMATION COLLECTED


In order to perform our services, we may collect certain information from you, and third parties we engage may also collect such information for the purpose of hosting, configuring, maintaining, operating, administering, designing and supporting our systems, and to provide services to the Financial Entities with whom you do business. We do not share your Personal Information with third parties other than as set forth in this Privacy Policy. Each Financial Entity’s privacy notice shall apply to you and your Personal Information, and you should refer to those privacy notices to understand how the Financial Entity uses and processes your Personal Information. CUDC is not responsible, nor liable, for the practices, privacy notices and their content, of third parties, including the Financial Entities with whom we, and you, do business. Personal Information that CUDC may collect includes, but is not limited to, the following categories of information (“Personal Information”):

  • Contact (i.e., first/last name, mailing or property address, phone number, email address)
  • Loans (i.e., loan number, account number)
  • Other personal information required by Financial Entities in order to provide services to you

BROWSING INFORMATION


Like most online services, we collect standard technical, information when you use our Services, including, but not limited to unique device identifiers, internet protocol (IP) addresses, browser types, internet service providers (ISPs), the number and duration of page visits and the number of clicks. We may use cookies, which are small pieces of data stored on your device which include an anonymous unique identifier, for session purposes. We may use tracking systems for certain systems, and we recognize Do Not Track requests from internet browsers or similar devices with regard to consumers, but not for Financial Institution employees acting within the scope of their employment.


HOW WE COLLECT INFORMATION


Information about you may be collected by CUDC from the following sources:

  • Applications or other forms we receive from you or your authorized representative
  • Correspondence you or others send to us
  • Information we receive through our Information Channels, financial institutions, and third party providers
  • Information from consumer or other credit reporting agencies and public records maintained by government entities that we obtain directly from those entities, including your credit worthiness and credit history
  • Information we receive from other sources, as permitted by applicable, laws, and regulations

USE OF COLLECTED INFORMATION


The information we collect from you, or others on your behalf, is used for the following business purposes:

  • To provide products and services to you or any Financial Entity or other third party who is obtaining services on your behalf, or in connection with a transaction involving you
  • To communicate with you regarding your transaction or our products and services
  • To improve our products and services
  • To personalize your user experience regarding our Information Channels

WHEN INFORMATION IS DISCLOSED


We are permitted by law to provide your Personal Information to various companies and individuals, without obtaining your permission. Certain laws do not allow you to restrict these disclosures. In the section below entitled, “Your Information Choices,” we share with you how to limit certain disclosures of your Personal Information. CUDC may disclose information including, but not limited to, the following situations, to affiliates and third parties, unless otherwise restricted by applicable law:

  • To third parties to provide you with services you have requested, and to enable us to detect or prevent fraud, misrepresentation, or criminal activity
  • To third parties that provide services on our behalf and use the information only in connection with such services
  • To law enforcement or other government authorities in connection with an investigation, civil or criminal subpoena, or court order
  • To other third parties with whom you have given us written, including electronic, authorization to disclose your Personal Information
  • To investigate potential unauthorized use of our Information Channels
  • To share and use, for any purpose, the Personal Information if it is in an aggregated, anonymized form, so that you are not identified (collectively, “De-Identified Data”)
  • In connection with a sale, transfer or other disposition of all or part of CUDC’s business/assets, or in the event of bankruptcy, reorganization, receivership, insolvency, or assignment for the benefit of creditors
  • For any purpose disclosed by us to you when you provide the information, and as directed by you, or with your permission
  • (i) to understand and analyze trends and preferences; (ii) to monitor and analyze our Services’ effectiveness; (iii) to improve our Services and develop new products, services, features, and functionality; (iv) to personalize our Services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you use our Services, and (v) to provide customized content and information.

YOUR INFORMATION CHOICES


CUDC may use your Personal Information for the following purposes, which such use cannot be limited by you:

  • For our everyday business purposes – to process your transactions, respond to law enforcement or other government authorities regarding an investigation, and subpoenas or court orders
  • For our own marketing purposes
  • For joint marketing with financial companies
  • For our affiliates’ everyday business purposes, we may share information about your transaction and experiences

You may choose to prevent CUDC from disclosing or using your Personal Information in the following circumstances:

  • For our affiliates’ everyday business purposes – information about your credit worthiness
  • For our affiliates to market to you

UPDATES AND CORRECTIONS


To update or correct your Personal Information in our possession, please contact us as specified at the beginning of this Privacy Policy. Please be advised, in those cases where we are acting as a third-party service provider to a Financial Institution, you must contact your Financial Institution to update or correct your Personal Information. (See The California Online Privacy Protection Act below for additional information.)

California Residents: Under California’s “Shine the Light” law, California residents who provide certain personally identifiable information in connection with obtaining products or services for personal, family, or household use are entitled to request and obtain from us, limited to once a calendar year, information about customer information we may have shared (if any) with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities, if any). To obtain this information, please send an email message to privacy@cudirect.com with “Request for California Privacy Information” in the subject line and in the body of your email. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements, and only information on covered sharing will be included in our response. California users are entitled, under California Civil Code Section 1789.3, to the following consumer rights notice: If you have a question or complaint regarding the services or products provided through our systems, please send an email to privacy@cudirect.com. You may also contact us by writing to CU Direct Corporation, 18400 Von Karman, Suite 900, Irvine, CA 92612, Attn: PRIVACY, or by calling us at 1-877-744-2835 (Toll-free). California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

For Nevada Residents: Nevada law allows marketing calls to existing customers even if you are listed on the national Do Not Call list; however, we do not market to consumers. Nevada law requires that we also 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; Phone number: 702.486.3132; email: BCPINFO@ag.state.nv.us.

For Oregon Residents: We will not share your Personal Information and/or Browsing Information with nonaffiliated third parties for marketing purposes, except after you have been informed by us of such sharing and had an opportunity to notify us that you do not want us to disclose your Personal Information for marketing purposes.

For Vermont Residents: We will not share your Personal Information and/or Browsing Information with nonaffiliated third parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account. We will not share information about your creditworthiness with our affiliates except with your authorization. For joint marketing in Vermont, we will only disclose your name, contact information and information about your transactions.


The California Online Privacy Protection Act

As noted above, in many instances we are acting as a third-party service provider to a Financial Institution. In those instances, we may collect certain information on behalf of such Financial Institution. During these transactions, we may collect some or all of the information on behalf of the Financial Institution that is described in the section above titled Types of Information Collected. Your submitted information is then transferred to your Financial Institution by way of our services. The Financial Institution is solely responsible for taking action or making changes to any consumer information that is submitted through our systems. If you believe that your user information is incorrect, you must contact your Financial Institution. We generally retain the information that you submit to us for 90 days. In some instances, we may retain the information indefinitely as not otherwise restricted by law or order. If we receive a timely request from you, we can provide the information to the applicable Financial Institution that is acting on your behalf before we purge our workspace of such information. If you are receiving consumer services and have questions regarding the choices you have with regard to your personal information or how to access or correct your personal information, you should contact your Financial Institution.