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Last updated March 26, 2019
Credit Union of Texas (“CUTX”) is a Federal Credit Union headquartered in Dallas, Texas. Our parent company is Credit Union Services Inc. (“CUSI”). CUTX, along with CUSI and its subsidiaries (including Texas Mortgage Lending, LLC.; FairLease Auto Leasing; and CUSO Financial Services, LP) is engaged in providing financial products and services to our Members. For more information on on CUTX or CUTX Membership, please see https://www.cutx.org/about-us.
Your privacy is important to us. This Online Privacy Statement (the “Statement”) describes CUTX’s online privacy practices. This Statement applies to all CUTX online services and any CUTX U.S. affiliate or subsidiary online service. The Term “CUTX” or “we” or “us” or “our” in this Statement refers to the CUTX U.S. affiliates or subsidiaries of CUSI. This Statement explains how we collect, share, use and protect information when you visit or use the online services provided by CUTX and other CUTX subsidiaries in the United States. It applies to anyone accessing or using a CUTX website or online service, whether the user is a Member of CUTX or not. This Statement also explains how information may be collected and used for advertising and marketing purposes.
Credit Union of Texas is committed to helping protect your privacy and to developing technology that can provide you a powerful and safe online experience. By using our online services, you consent to the data practices described in this Statement.
Credit Union of Texas will update this Online Privacy Statement occasionally to reflect company and customer feedback or changes in our online offerings and services. We encourage you to review this Statement periodically to remain informed of our online practices.
Collection of your Personal Information
Information We Collect
Credit Union of Texas collects personally identifiable information (“Personal Information”), such as information you provide via forms, surveys, applications or other online fields (including your e-mail address, account numbers, name, and home or work addresses or telephone or mobile numbers). Credit Union of Texas also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites. We collect and use such information only where we reasonably believe the information will be necessary or useful in providing you with the products and services you request from us, as well as to help us identify new opportunities to provide products, services and information to help you achieve financial success. The information we collect and use about you helps us to maintain the security of your accounts with us, improve the customer service we provide to you, and operate more efficiently.
There also is information about your computer hardware and software that is automatically collected by Credit Union of Texas. This information can include: your IP address, browser type, domain names, access times and referring Web site addresses. This information is used by Credit Union of Texas for the operation of its online services, to maintain quality of the services, and to provide general statistics regarding use of the Credit Union of Texas Web site.
Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Credit Union of Texas public message boards, this information may be displayed, collected and used by others.
Credit Union of Texas encourages you to review the privacy statements of Web sites you choose to link to from our sites or advertising so that you can understand how those Web sites collect, use and share your information. Credit Union of Texas is not responsible for the privacy statements, privacy policies or other content on web sites outside of the Credit Union of Texas and Credit Union of Texas family of websites.
Use of your Personal Information
Credit Union of Texas may use any Personal Information:
- To respond to your inquiries and fulfill your requests;
- To inform you about important information regarding our online services, products or other service for which you apply or may be interested in applying for, or in which you are enrolled;
- To inform you of changes to terms, conditions and policies and/or other administrative information regarding your interactions with us, your accounts, or services that you use or in which you have expressed an interest;
- To deliver marketing communications that we believe may be of interest to you, including advertising or offers tailored to you;
- To personalize your experience with our online services;
- To allow you to apply for products or services (e.g., to pre-qualify for a mortgage, apply for a credit card, or to open an investment account or other financial product) and evaluate your eligibility for such products and services;
- To verify your identity and/or location (or the identity or location of your representative or agent) in order to allow access to your accounts, conduct online transactions and to maintain measures aimed at preventing fraud and helping to protect the security of your account and Personal Information);
- Collected through aggregation services such as Bankrate that we provide or use, in order to consolidate your financial account information at one online location and to understand what products or services may be of interest to you and to present you with offers;
- Collected through our social media pages and other online interactions with you to assist in verifying your identity or account status. We may combine this online information with information collected from offline sources or other information we already have or may acquire;
- For business purposes, including data analysis audits, developing and improving products and services, enhancing our online services, identifying usage trends and determining the effectiveness of promotional campaigns;
- For risk control, for fraud detection and prevention; to comply with laws and regulations; and to comply with other legal process, regulatory and/or law enforcement requirements; and
- To allow you to utilize features within our online service by granting us access to information from your device such as contact lists or geo-location when you request certain services.
Credit Union of Texas does not sell, rent or lease its customer lists to third parties. Credit Union of Texas may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, Credit Union of Texas may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Credit Union of Texas, and they are required to maintain the confidentiality of your information.
Credit Union of Texas does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.
Credit Union of Texas keeps track of the Web sites and pages our customers and others visit within the Credit Union of Texas sites, in order to determine what Credit Union of Texas services are the most popular. This data is used to deliver customized content and advertising within Credit Union of Texas to customers and potential members whose behavior indicates that they are interested in a particular subject area, product or service.
Credit Union of Texas may share your personal information with service providers with whom we work, such as data processors and companies that help us market products and services to you. When permitted or required by law, we may share your personal information with additional third parties for purposes including response to legal process.
We respect the privacy of our Members and other users of our websites. When you use our online services or mobile applications, we do not allow unaffiliated third parties to collect personally identifiable information about you when you use our website or mobile applications.
We do use online tracking technologies, such as cookies or click stream auditing, for our own internal uses, such as to monitor and maintain information about your visits to our sites, to help us identify and address problems, to improve our sites, to analyze web traffic trends, and to protect the security and integrity of our online services. Our affiliates also may use online tracking technologies to recommend products and services.
- Through your browser or device: Certain information is collected by most browsers and/or through your device, such as your Media Access Control (MAC) address, device type, screen resolution, operating system version and internet browser type and version. We use this information to ensure our online services function properly, for fraud detection and prevention, and security purposes.
- One of the primary purposes for using cookies is to provide a convenience feature to users of a website. A cookie tells the web server that you have returned to a specific page. For example, if you personalize Credit Union of Texas pages or register with Credit Union of Texas sites or services, a cookie helps Credit Union of Texas to recall your specific information on subsequent visits.
- Cookies are used in the online banking login process to identify a user’s computer to help better enhance security. If a cookie is not on the computer or the use changes computers, the user will be asked to re-authenticate.
- Cookies cannot be used to capture your e-mail address, obtain data from your hard drive, or gain confidential or sensitive information about you. You may be shown CUTX text and/or image ads on any Google or other third party internet sites for a limited period of time. You may opt out of re-marketing by visiting Google’s Ads Settings (https://adssettings.google.com). You also may opt out of receiving targeted ads from many websites by option out of network advertising programs. Opting out from a specific advertising network means only that the ads you do receive online will be generic and not based on your preferences or behavior.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you usually can modify your browser settings to decline cookies if you prefer. You will need to manage your cookie settings for each device and browser you use. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Credit Union of Texas service or websites you visit. For example, we will not be able to recognize your device and you will need to answer a challenge question each time you log on. You also may not receive tailored advertising or other offers from us that may be relevant to your interests and needs.
Additionally, when “Do Not Track” or another mechanism is enabled on a web browser, we do not respond to or take any action with respect to such configuration. That is, we do not disable tracking.
- Other technologies including pixel tags, web beacons, and clear GIFs: These technologies may be used in connection with some website pages, downloadable mobile applications and HTML-formatted email messages to measure the effectiveness of our communications and our marketing campaigns, to compile statistics about usage and response rates, to personalize/tailor your experience while engaging with us online and offline, and to assist us in resolving issues that may arise on our websites.
- Flash objects: As part of our solutions for online authentication, we use Flash objects (sometimes referred to as “Local Shared Objects”) to help us recognize you and your device when you come back to our online services. For our pages running Adobe® Flash® content (demos and tutorials with moving content), we use Flash objects to determine your browser type and version of Adobe Flash in order for you to view the content. We do not use Flash objects for any online behavioral advertising purpose. Deleting cookies does not delete Flash objects. You can learn more about Flash objects - including how to control and disable them - through the Adobe interface. If you choose to disable Flash objects from our Site, then you may not be able to access and use all or part of our websites or benefit from the information and services offered.
- Click Stream Auditing: This process collects and analyzes information such as a web user’s IP address, web pages which referred a user to our website, date and time, domain type, and when a web user has responded to an advertisement.
- IP Address: Your IP Address is a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits our websites , along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating website usage levels, helping diagnose server problems, to personalize/tailor your experience while engaging with us online and offline, for compliance and security purposes, for advertising, and administering the Site. Please see the Advertising section below for more information.
- Aggregated and De-identified Data: Aggregated and De-identified Data is data that we may create or compile from various sources, including but not limited to accounts and transactions. This information, which does not identify individual account holders, may be used for our business purposes, which may include offering products or services, research, marketing or analyzing market trends, and other purposes consistent with applicable laws.
Third party widgets – We may allow certain widgets (e.g., social share buttons) on our websites that enable users to easily share information on another platform, such as a social media platform. The third parties that provide these widgets may have access to information about your browsing on pages of our websites where these widgets are placed. You may wish to review information at the third party site, such as social media platforms where you have an account, to determine how these third parties collect and treat such information. Also, see Linking to Other Sites and Social Media Sites below
CUTX advertises online (through our websites and mobile applications, through our social media presences, and on other sites and mobile apps not affiliated with CUTX) and offline (in our credit union’s physical sites, through call centers, and through direct marketing).
We use third party advertising and media companies to serve ads on our behalf across the internet and to help manage and optimize our internet business and digital communications. These networks use both cookies and pixel tag technology, which do not contain your personally identifiable information, to assist us in measuring the effectiveness of our ads. These technologies work by using your visits to other websites to provide information to us about goods and services that may be of particular interest to you.
We limit these networks from using the information collected by these cookies and pixel tags for any purpose other than to assist us in our advertising efforts. From time to time, we also may share anonymous information with such third party companies in an aggregate form, for purposes of analysis and improvement of our website.
CUTX uses the information described in this Statement to help advertise our products and services, including pre-screened offers of credit, in a variety of ways. We use this information to:
- Present tailored ads to you, such as:
- Banner ads and splash ads that appear as you sign on or off of your online accounts on our website, and within mobile banking and other mobile apps;
- Email, postal mail and telemarketing; and
- On other sites and mobile apps not affiliated with CUTX.
- Analyze the effectiveness of our ads; and
- Determine whether you may be interested in our products and services.
Text Communications and Marketing.
Children’s Online Privacy Protection Act (COPPA)
The Children’s Online Privacy Protection Act (COPPA) was passed to give parents increased control over what information is collected from their children online and how such information is used. The law applies to websites and other services directed to, and which may collect information from, children under the age of 13. CUTX respects the online privacy of children. Our websites and online services are not directed at children under the age of 13, nor do we knowingly collect, maintain, or use personally identifiable information from them.
Linking to Other Websites
We may provide links to third party sites, such as credit bureaus, service providers or merchants. If you follow links to sites not affiliated or controlled by CUTX, you should review their privacy and security policies and other terms and conditions, as they may be different from those of our websites. CUTX does not guarantee and is not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of their information.
Social Media Sites
Security of Your Personal Information
Credit Union of Texas secures take care to safeguard the information we collect and use about you. We do not share access to the information about you that we collect, unless doing so is necessary to provide you the products and services that are part of your relationship with CUTX.
Credit Union of Texas maintains reasonable physical, electronic and procedural safeguards to protect your nonpublic personal information.
Changes to this Statement
Credit Union of Texas will occasionally update this Statement of Privacy to reflect company and customer feedback. Credit Union of Texas encourages you to periodically review this Statement to be informed of how Credit Union of Texas is protecting your information.
Social Security Number Protection Policy
Social Security numbers may only be accessed by and disclosed to Credit Union of Texas employees and others with a legitimate business “need to know” in accordance with applicable laws and regulations. Social Security numbers, whether in paper or electronic form, are subject to physical, electronic, and procedural safeguards, and must be stored, transmitted, and disposed of in accordance with the provisions of the credit union policies. These restrictions apply to all Social Security numbers collected or retained by Credit Union of Texas in connection with Member, employee, or other relationships.
Credit Union of Texas welcomes your comments regarding this Online Privacy Statement. If you have any concerns about this Statement, please contact Credit Union of Texas at here. We will use commercially reasonable efforts to promptly review your concerns and remedy the problem.