Privacy

Last Revised: February 2, 2023

 

1. General

We know that your privacy is important to you, and we work hard to earn and keep your trust.  Purdue Federal Credit Union (“Company,” “we,” “us,” and “our”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”). 

This Policy describes:

• The types of information we collect from you or that you may provide when you visit our website available at: https://www.purduefed.com/ (the “Website”), our Purdue Federal Digital Banking mobile application (the “Application”), as well as any websites and blogs directly owned by the Company where this Policy is linked (collectively, with the Website and the Application, our “Platform”).  
• Our practices for collecting, using, maintaining, protecting, and disclosing that information. 

This Policy applies to information we collect on this Platform or in emails and other electronic messages between you and this Platform, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy. 

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Platform (for further information, see below, “Third-party Websites”). 

Please read this Policy carefully to understand our practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, then please do not use our Platform.  By using our Platform, you agree to the terms of this Policy.  This Policy may change from time to time (see below, “Changes to this Policy”).  Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates. 

2. Privacy Notice; California Privacy Disclosure

This Policy is incorporated by reference and should be read in conjunction with the Company’s (1) Privacy Notice and (2) California Privacy Disclosure.

Some information that you provide may be subject to other laws and regulations, including but not limited to Federal Gramm-Leach-Bliley Act (Public Law 106-102), and the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the Financial Code). Such information may be related to our financial products and services. For more information please refer to our Privacy Notice.

3. What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this Policy.  Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). In particular, the Platform may collect the following Personal Information from users of the Platform:

• Personal identifiers: real name; postal address; Social Security Number or other identifying number; driver’s license number; telephone number; email address.
• Characteristics of protected classifications: gender; age; marital status.
• Biometric information: fingerprint; face, voice recordings; keystroke patterns.
• Commercial Information: records of personal property; products or services applied for or obtained; purchasing tendencies.
• Internet activity: browsing history; search history; information in relation to our website, applications or advertisements.
• Geolocation data: IP address; device location; any information used to identify your physical location.
• Financial details: bank account numbers; debit/credit card numbers; transaction details.
• Inferences: Any derivation of information, data, assumptions, or conclusions from any information or data collected used internally for business purposes.

We obtain the Personal Information listed above from the following categories of sources:

• Directly from you. For example, when you: 
  • register yourself with the Platform;
  • participate in available sweepstakes;
  • participate in, submit a request for, or register for a seminar or webinar;
  • subscribe to one of our e-newsletters; 
  • schedule an appointment, such as a counseling appointment;
  • submit a job application; 
  • submit an online application;
  • provide feedback or information regarding sponsorships and programs; or 
  • otherwise communicate with us, such as communicating via a live chat or requesting more information.
• Indirectly from you. For example, through information we collect from you in the course of providing our services to you.
• Directly and indirectly from activity on our Platform. For example, from Platform usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section below. 

Free-Text Boxes. The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Company to request further information.  When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.  

Username and Password; Other Sources. We may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous.  Additionally, we may receive information about you from other sources and add it to the information you have provided to us.

Aggregated and De-Identified Data.  We also collect, use and share Aggregated and De-Identified Data such as statistical or demographic data for any purpose. Aggregated and De-Identified Data could be derived from your Personal Information but is generally not considered Personal Information under applicable law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated or De-Identified Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.

4.  Automated Information Collection

Website. In addition to the information that you provide to us, we may also collect information about you during your visit to our Website.  We collect this information using automated tools that are detailed below.  These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website.  Some of the tools we use to automatically collect information about you may include:

Cookies.  A “cookie” is a small data file transmitted from a website to your device’s hard drive.  Cookies are usually defined in one of two ways, and we may use either (or both) of them:  

1. session cookies, which do not stay on your device after you close your browser, and 
2. persistent cookies, which remain on your device until you delete them or they expire.  

We may use the following categories of cookies on our Website:

1. Strictly Necessary Cookies.  These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested, such as maintaining a record of your application for our services, cannot be provided.
2. Performance Cookies.  These cookies collect anonymous information on how you use our Website to help us understand how you arrive at our Website, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
3. Functionality Cookies.  These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized.  These cookies cannot track your browsing activity on other websites.
4. Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign.  The cookies are usually placed by third-party advertising networks.  These cookies remember the websites you visit and that information is shared with other parties, such as advertisers. 

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings.  However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.

1. Google Analytics.  The Website sends aggregated non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance.  For more information on how Google Analytics supports the Website and uses information sent from the Website, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.
2. Meta Pixel.   With the help of the Meta pixel, also known as the Facebook Pixel, Meta is able to determine the visitors of our Platform as a target group for the presentation of advertisements. With the help of the Meta pixel, we want to make sure that our ads are in line with the potential interest of users and do not have a nuisance effect.  Using the Meta pixel, we can also track the effectiveness of Meta or Facebook ads for statistical and market research purposes.  Meta’s processing of the data is governed by Meta’s Data Usage Policy, which is available at https://www.facebook.com/policy.php.  For specific information and details about the Meta pixel and how it works, please visit the Meta Business Help Center: https://www.facebook.com/business/help/651294705016616.
3. Hotjar. Another trusted third party partner that tracks Platform user behaviors is Hotjar. You can opt-out of tracking by Hotjar here: https://www.hotjar.com/opt-out/ and can learn about Hotjar’s ability to use and share information through the Hotjar Terms & Conditions of Use, available at https://www.hotjar.com/terms, and the Hotjar Privacy Policy, available at https://www.hotjar.com/privacy/.
4. LinkedIn Insight Tag.  Within the Website, the marketing functions of the network LinkedIn may be used. The LinkedIn Insight Tag is a piece of lightweight JavaScript code that we have added to the Website to enable advertisement campaign reporting and to help us unlock valuable insights about our Website visitors. The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamp, and events such as page views. You can opt out on this link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.  For more information on the LinkedIn Privacy Policy, go to https://www.linkedin.com/legal/privacy-policy. 
5. Web Beacons.  A Web Beacon is an electronic image.  Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior.  If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails.  We may also use them to track if you click on the links and at what time and date you do so.  Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Website.  This information is only collected in aggregate form and will not be linked to your Personal Information.  Please note that any image file on a webpage can act as a Web Beacon.
6. Embedded Web Links.  Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link.  The tracking is accomplished through a redirection system.  The redirection system allows us to understand how the link is being used by email recipients.  Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you.  This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
7. Third-party Websites and Services.  We work with a number of service providers of marketing communications technology.  These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide.  The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing.  For example, we may collect data where our banner advertisements are displayed on third-party websites.

Application. In addition to the information that you provide to us, we may also collect information about you during your visit to our Application.  We collect this information using automated technology.  This technology may collect information about your behavior and your device, such as your internet address (IP Address), the pages you have viewed, the actions you have taken while using the Application, saved preferences, and log-in Session ID.  This information is not personally identifiable or capable of being used to identify you in the scope of this Policy. 

5.  How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to: 

• providing the information, products and services you request;
• security, credit or fraud prevention purposes;
• providing you with effective customer service;
• providing you with a personalized experience when you use this Platform;
• contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• contacting you with information and notices related to your use of this Platform;
• inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
• better understanding your needs and interests;
• improving the content, functionality and usability of this Platform;
• improving our products and services;
• improving our marketing and promotional efforts; and
• any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

Duration. The length of time Company intends to retain Personal Information, including sensitive information, if any, is for as long as reasonably necessary to carry out Company’s intended business purpose for such information.  

6.  How We Disclose Your Information

We do not sell or lease your Personal Information to any third party.  We may disclose your Personal Information to a third party for a business purpose. We may disclose your Personal Information for a business purpose to the following categories of third parties: 

• Our affiliates. We may share the information collected through the Platform with our affiliates.
• Third-party Service Providers. We share Personal Information collected through the Platform with third-party service providers who act for or on behalf of the Company. For example, we may use third-party vendors to design, operate, and/or host our Platform, to conduct surveys, to help us with our marketing and promotional efforts (including targeted advertising), fulfill orders, and to bill users for good and services. These third parties may need information about you to perform their functions.
• With Other Carefully Selected Business Partners. From time to time, we may share your Personal Information with selected third parties (other than our service providers). For example, we partner with third parties to sponsor contests or other promotions, and we may share with these third parties the Personal Information you submit to us to participate in the contest or take advantage of the promotion. Before doing so, however, we may offer you the opportunity to “opt out” or “opt in” as required by applicable law. 
• With Third-Party Social Media Platforms. We may provide functionality on the Platform that allows you to automatically post information to a third-party social media platform (such as Facebook, Twitter, or Pinterest). If you choose to take advantage of this functionality, people who can view your profile on the third-party platform will be able to see your post. Thus, you should have no expectation of privacy in those actions.
• In Aggregate or De-Identified Form. We use information collected through the Platform to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties so we and they can better understand our user base. 

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:  

• Legal Reasons.
  • We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
  • To respond to duly authorized information requests from law enforcement or other governmental authorities;
  • To enforce our agreements or policies;
  • To investigate and prevent security threats, fraud, or other malicious activity; or
  • To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.
• Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business.  Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.

7.  Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information. 
If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed.  Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

From time to time, we may send you email newsletters and marketing emails.  You may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. 

8.  Text Messaging 

You may have the opportunity to receive SMS or "text" messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties.  Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested.  In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number.  In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us.  You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications to you.  Message and data rates may apply.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.  

9.  Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing. 

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security.  We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.  

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

10.  Information of Minors

For individuals within the United States, we do not knowingly collect or use information from individuals under the age of thirteen (13) without parental or guardian consent.  For individuals outside of the United States, we do not knowingly collect or use information from individuals under the age of sixteen (16) without parental or guardian consent.  We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet.  If we are aware of any Personal Information that we have collected about minors without parental or guardian consent, we will take steps to securely remove it from our systems. 

11.  Submissions 

We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, ideas, materials, comments or other information you provide to us (collectively, “Submissions”) will be treated as non-proprietary and non-confidential. Your Submissions on or through this Platform are available to others who visit this Platform. In addition, we may use your Submissions in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Submissions for such purposes. Therefore, you should have no expectation of privacy with respect to your Submissions on or through this Platform. You should not submit any content you do not wish to make available to the general public. Your Submissions must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Submission. 

12.  Third-party Websites 

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates.  Our Platform may link to third-party websites and services. For example, if you click on an advertisement on this Platform, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them.  Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.  

13.  Your California Rights

If you are a California consumer, as that term is defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, you may have additional rights to your Personal Information.  For more information regarding these rights, please review our California Privacy Disclosure. 

14.  Location of our Services

We do not warrant or represent that this Policy or the Platform’s use of your Personal Information complies with the laws of every jurisdiction.  Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours.  Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.  

15.  Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.  However, we can never promise 100% security.  You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password.  If you believe your credentials have been compromised, please change your password. Please also notify us immediately of any actual or suspected unauthorized use at 1-800-627-3328.      

16.  Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through this Platform. We are continually improving and adding to the features and functionality of this Platform along with the products and services we offer through this Platform. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

17.  How to Contact Us

We value your opinions and welcome your feedback.  To contact us about this Policy or your Personal Information, please contact us by email at [email protected] or by mail at:

Purdue Federal Credit Union
PO Box 1950
West Lafayette, IN 47996

 

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See also:

Privacy Notice
California Privacy Disclosure