California Consumer Privacy Statement

 

This California Privacy Statement is for California Residents only and supplements [the Privacy Notice]. This policy describes the personal information that Great Lakes Credit Union (“we,” “our,” or “us”) collects in the course of its business, explains how this information is collected, used, shared, and disclosed, describes rights provided by the California Consumer Privacy Act of 2018 (“CCPA”) to (“consumers” or “you”) regarding their personal information, and explains how consumers can exercise those rights.

 

What is Personal Information?

We may collect, use, or share your personal information.  Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“personal information”). “Personal information” does not include: (1) publicly available information, such as information that is lawfully made available from federal, state, or local records, and (2) de-identified or aggregate consumer information.

With a limited exception, and as noted in other sections of this privacy policy, certain provisions of the CCPA do not apply to:

  • Certain personal information covered by or collected under industry-specific federal and state privacy laws including, but not limited to, the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver's Privacy Protection Act of 1994.
  • Personal information that we collect about you when you are acting as our job applicant, employee, owner, director, officer, medical staff member, or contractor to the extent that we collect and use your personal information solely within the context of that role. This also includes your emergency contact information and personal information that is necessary for us to retain to administer benefits for you.  However, you will still receive a notice at the time of collection, which outlines the categories of personal information we collect and the purposes for which we collect the categories of personal information.
  • Personal information we receive from you reflecting a communication or transaction between us and another business when you are acting as an employee, owner, director, officer, or contractor of such company, partnership, sole proprietorship, nonprofit, or government agency and you are seeking a product or service from us for the company, partnership, sole proprietorship, nonprofit, or government agency (Business Consumer). We have outlined the limited rights afforded to Business Consumers below.

 

Personal Information We Collect, Use, or Share

The CCPA requires us to disclose certain information regarding our collection, use, and sharing of personal information.


Collecting Your Personal Information

In the past 12 months, we have collected the following categories of personal information:

  • This may include a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
  • Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)). This may include a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
  • Characteristics of Protected Classification under California or Federal Law. This may include age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  • Commercial information. This may include records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Biometric information. This may include genetic, physiological, biological, or behavioral characteristics that can be used, singly or in combination with each other or with other identifying data, to establish your identity, including deoxyribonucleic acid (DNA), fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
  • Internet or other similar network activity. This may include browsing history, search history, or information on a consumer's interaction with a website, application, or advertisement.
  • Geolocation data. This may include physical location or movements.
  • Sensory data. This may include audio, electronic, visual, thermal, olfactory, or similar information.
  • Professional or employment-related information. This may include current or past job history or performance evaluations.
  • Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)). This may include education records directly related to a student maintained by an educational institution or party acting on its behalf, such as report cards, transcripts, class lists, student schedules, student identification codes, student financial information, and student disciplinary records.
  • Inferences drawn from other personal information. This may include information, data, assumptions, or conclusions derived from facts, evidence, or another source of information or data reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.


In the past 12 months, we have collected personal information from the following categories of sources:

  • Consumers Including You
  • Members
  • Great Lakes Credit Union’s Employer Sponsors
  • Job Applicants
  • Employees
  • Contractors
  • Consumer Reporting Agencies
  • Collections Agencies
  • Service Providers
  • Government Agencies
  • Data Resellers
  • Internet Service Providers
  • Mobile Service Providers


We may collect your personal information for the following business or commercial purposes:

  • Account Services: We use personal information to offer our account services, including: (1) establishing, maintaining, supporting, and servicing an account you may have opened with us and for which you provided the information or that you may have applied for or established with us;  (2) providing services, products, or information you may have requested from us; and (3) performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on our own behalf or on the service provider’s behalf.
  • Security and Fraud Detection: We use personal information for our security and fraud detection services including: detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
  • Debugging: We use personal information to engage in debugging to identify and repair errors that impair existing intended functionality.
  • Improvement of Products and Services: We use personal information to verify, maintain, and improve our products and services.
  • Internal Research: We use personal information for our internal research related to technological development and demonstration.
  • Advertising and Marketing Services: We use personal information to provide advertising or marketing services on our own behalf.
  • Legal Obligations: We use personal information to comply with legal obligations.
  • Audits: We use personal information to audit current interactions with you and related transactions (e.g., counting and verifying ad impressions, auditing compliance).
  • Merger/Acquisition/Bankruptcy, etc.:  We may use your personal information as part of a merger, acquisition, bankruptcy, or other transaction where a third party assumes control of us.
  • Commercial/Economic Interests: We use personal information to advance our commercial or economic interest.

Disclosing Your Personal Information for a Business or Commercial Purpose

We may disclose your personal information to service providers and third parties in order to carry out specific business or commercial purposes. In the preceding 12 months, we have disclosed the following categories of consumer personal information for business or commercial purposes to service providers and the following categories of third parties:

  • Identifiers to Loan or Account Servicing Contract Partners, Consumer Reporting Agencies, Other Financial Institutions, Marketing Firms, Data Analytics Firms, Government Entities, Operating System Providers, Joint Marketing Partners, Financial Aggregators.
  • Personal information described in the California Customer Records Statute to Loan or Account Servicing Contract Partners, Consumer Reporting Agencies, Other Financial Institutions, Marketing Firms, Data Analytics Firms, Government Entities, Operating System Providers, Joint Marketing Partners, Financial Aggregators.
  • Characteristics of Protected Classification under California or Federal Law to Loan or Account Servicing Contract Partners, Consumer Reporting Agencies, Other Financial Institutions, Marketing Firms, Data Analytics Firms, Government Entities, Operating System Providers, Joint Marketing Partners, Financial Aggregators.
  • Commercial information to Loan or Account Servicing Contract Partners, Operating System Providers, Data Analytics Firms, Joint Marketing Partners, Consumer Reporting Agencies, Government Entities, Marketing Firms, Other Financial Institutions.
  • Biometric information to Loan or Account Servicing Contract Partners, Government Entities, Data Analytics Firms, Operating Systems Providers.
  • Internet or other similar network activity to Loan or Account Servicing Contract Partners, Marketing Firms, Data Analytics Firms, Social Networks, Government Entities, Other Financial Institutions, Joint Marketing Partners.
  • Geolocation data to Loan or Account Servicing Contract Partners, Government Entities, Data Analytics Firms, Other Financial Institutions, Marketing Firms, Joint Marketing Partners, Operating Systems Providers.
  • Sensory data to Loan or Account Servicing Contract Partners, Government Entities, Operating Systems Providers.
  • Professional or employment-related information to Loan or Account Servicing Contract Partners, Other Financial Institutions, Government Entities, Data Analytics Firms, Consumer Reporting Agencies, Marketing Firms, Operating Systems Providers.
  • Non-public education information (per the Family Educational Rights and Privacy Act to Loan or Account Servicing Contract Partners, Government Entities.
  • Inferences drawn from other personal information to Loan or Account Servicing Contract Partners, Consumer Reporting Agencies, Data Analytics Firms, Marketing Firms, Government Entities, Other Financial Institutions, Operating Systems Providers.

In the preceding twelve (12) months, we have not sold any personal information. In addition, we do not sell personal information. Also, it is our business practice not to sell the personal information of minors under 16 years of age and we have no actual knowledge of doing so.

 

Your Rights under the CCPA

As described in more detail below, the CCPA provides you with certain rights regarding the collection, use, and disclosure of your personal information.  The CCPA also provides consumers with certain rights (for example, opt-out rights) if a business sells personal information, which we do not do.

The Right to Know About Personal Information Collected, Used, or Disclosed

You have the right to request that we provide you with certain information about the personal information we collect, use, or disclose about you as well as the categories and specific pieces of information that we have collected about you in the 12 months before your submission of a verifiable consumer request.  Specifically, you have the right to request the following information:

  • The specific pieces of personal information we have about you.
  • The categories of personal information we have collected about you, including:
    • The categories of personal information we have collected about you in the past 12 months.
    • The categories of sources from which the personal information about you was collected.
    • Our business or commercial purpose for collecting your personal information.
    • If we shared your personal information:
      • The categories of personal information that we disclosed about you for a business purpose in the past 12 months and, for each category identified, the categories of third parties to which it disclosed that particular category of personal information; and
      • The categories of third parties that we share personal information.

A household may request to know aggregate household personal information by submitting a verifiable consumer request.  Also, unless the household has a password-protected account, if all consumers in a household jointly request access to specific pieces of information for the household, we can individually verify the identity of all the members of the household, and we can verify that each member is a current member of the household, then we will comply with the request.

However, there is certain information that we will not disclose to you.  This information includes but is not limited to your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answer, or unique biometric data generated from measurements or technical analysis of human characteristics.

This right does not apply to Business Consumers.

The Right to Request Deletion of Personal Information

You have the right to request that we delete any personal information that we have collected from you and maintained about you. Once we receive and confirm your verifiable consumer request, if we determine that we must comply with a deletion request and delete your personal information from our records, we will also direct any service providers we work with to also delete your personal information from their records.  If we store any of your personal information in our archived or back-up systems, we will delete your information once the systems are accessed, restored, and/or used.

A household may request the deletion of aggregate household personal information by submitting a verifiable consumer request.  In addition, unless the household has a password-protected account, if all consumers in a household jointly request deletion of household personal information, we can individually verify the identity of all the members of the household, and we can verify that each member is a current member of the household, then we will comply with the request.

Please note that we may deny your deletion request for a number of different reasons, which are identified in the CCPA. 

This right does not apply to Business Consumers.

 
Exercising Your Rights under the CCPA

Submitting a Verifiable Request to Know or Request to Delete

To exercise your Right to Know or your Right to Delete, please submit a verifiable consumer request to us by either:

  • Calling us at 1-800-982-7850.  When calling us, inform the call center agent that you are calling to submit a Verifiable Request to Know and provide the information requested by the agent for identity verification purposes.
  • Visiting www.glcu.org/ccpa-request-form.  When visiting www.glcu.org/ccpa-request-form, complete all required fields and click the submit button.

Only you (or an authorized agent) may make a verifiable consumer request. You may also make a verifiable consumer request on behalf of your minor child.

Verifying Your Identity

Once you submit your verifiable consumer request, we will verify your identity by matching the information you provided us with information in our systems. If you submit a request to know specific pieces of personal information or a request to delete certain information, in addition to verifying your identity with information we have on file, you also may be required to submit a signed declaration under penalty of perjury stating that the requestor is the consumer whose personal information is the subject of the request.  If we are unable to respond to your request for specific pieces of information, we will evaluate your request as if it is a request to know the categories of personal information that we have collected about you. 

If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account and we will also require you to re-authenticate yourself before we disclose your personal information.  If we suspect fraudulent or malicious activity on or from your account, we will not comply with your request until we perform further verification to determine whether your request is authentic and you are the person about whom we have collected the personal information.

We will generally avoid requesting additional information from you to verify you.  However, if we cannot verify your identity based on the information we currently maintain, we may request additional information from you, which will only be used to verify your identity and for security or fraud-prevention purposes.  We will delete any new personal information we collect to verify your identity as soon as practical after processing your request unless otherwise required by the CCPA.

Generally, if we are unable to verify your identity, we will deny your request and inform you of our inability to verify your identity and explain why we were unable to do so.  

Please note that we are only required to respond to your request for access to your personal information twice within a 12-month period.   

Responding to Your Request to Know or Delete

Once we receive your verifiable consumer request, we will confirm our receipt of your request within 10 business days and provide you with additional information about how we will process the request. Our goal is to respond to your request within 45 calendar days of receiving the request, beginning on the day we receive the request. However, in the event that we need more time (up to 90 calendar days) to respond to your request, we will provide you with notice and an explanation of the reasons that we will take more than 45 calendar days to respond. Any disclosures we provide will cover the 12-month period preceding the verifiable consumer request’s receipt.  If we are unable to comply with a given request, we will provide you with a response explaining why we have not taken action on your request and identifying any rights you may have to appeal the decision.

We will not charge you or your authorized agent to verify your identity.  In addition, we will not charge you or your authorized agent a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Authorized Agent for Requests

You may designate an authorized agent to make a request on your behalf. Unless you have a power of attorney, if you would like to use an authorized agent, which is an individual or business registered with the Secretary of State that you have authorized to act on your behalf, to submit a request, you must provide the authorized agent with written and signed permission to do so, verify your own identity directly with us, and directly confirm that you provided the authorized agent with permission to submit the request.  We may deny a request from an authorized agent that does not submit proof that they are authorized to act on your behalf.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. For example, unless otherwise permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you with a different level or quality of goods or services.
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.



Changes to Our California Privacy Statement

We are required by law to update this California Privacy Statement at least once each year. This California Privacy Statement was last updated on June 30, 2020.

 

Contact Information

If you have any questions regarding our privacy policies, our California Privacy Statement, the ways in which we collect, use, and disclose your personal information, or how to exercise your rights under the CCPA, please do not hesitate to contact us at:

Phone: 1-800-982-7850
Website: www.glcu.org/ccpa
Email:
Postal Address: P.O. Box 1289, Bannockburn, IL 60015
Attn: Risk Management, Senior Manager of Risk & Governance