Mobile Privacy Policy
as of October 2024


CU-Online (the “App”) helps you control your credit and/or debit cards through your mobile device, making it easy to manage your finances on the go.
The App allows you to:

• get real-time balances for your accounts
• manage your money
• view your transactions and statements
• make transfers
• pay your bills and manage billers
• deposit a check
• receive alerts
• manage cards

This Privacy Policy (“Privacy Policy” or “Policy”), in combination with other relevant privacy notices (“Privacy Notices”) that we provide to you (e.g., pursuant to financial privacy laws), inform you of the policies and practices regarding the collection, use and disclosure of any personal information that Sidney Federal Credit Union (“Sidney” or “we” or “us”) and our service providers collect from or about users in connection with the App’s mobile application (the “Services”). This Policy does not apply to information collected by any third party including through any application or content (including advertising) that may link to or be accessible from or on the App.
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use the App. By accessing or using the App or clicking “I accept,” you agree to this Privacy Policy. This Policy may change from time to time (see Privacy Policy Updates below). Your continued use of the App after we make changes shall indicate your acceptance of and agreement with those changes, so please check the Policy periodically for updates.

THE TYPES OF INFORMATION WE COLLECT IN THE APP
Through your use of the Services, we may collect personal information from you in the following ways:
(a) Personal Information You Provide to Us.
• We may collect personal information from you, such as your first and last name, address, e-mail, telephone number, and social security number when you create an account.
• We will collect the financial and transaction information necessary to provide you with the Services, including account numbers, payment card expiration date, payment card identification, verification numbers, and transaction and payment history.
• If you provide feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
• We also collect other types of personal information that you provide voluntarily, such as any information requested by us if you contact us via email regarding support for the Services.
The personal information you voluntarily provide via the App is already available to Sidney through other mechanisms, including by being a member of Sidney. Most of the information collected is used for security and verification purposes, or to communicate your account status to you.
(b) Personal Information Collected from Third Parties. We may collect certain information from third parties in order to provide some of our Services.

(c) Personal Information Collected Via Technology. We and our service providers may automatically log information about you, your device, and your interaction over time with our Services, our communications, and other online services, such as:
• Device data, such as your device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns. For example, when you visit the App again, the cookie allows the App to recognize your device. Cookies allow us to monitor usage of the App, improve the App’s usability and to personalize the content for you. If you do not wish to receive cookies, it may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or via your browser settings on a computer. However, if you select this setting, you may be unable to access certain parts of the App. Unless you have adjusted your settings so that it will refuse cookies, our system will issue cookies when you direct your device to the App.
• Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect location data when you use the Services even when the App is closed or not in use; for example, to provide our fraud detection services. If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.

THIRD PARTY COOKIES AND TRACKING TECHNOLOGIES

Third-party service providers may also place their own cookies on your device. These third parties include those we engage as well as other third parties, such as your mobile device manufacturer or your mobile service provider. These third parties may use cookies or other tracking technologies to collect information about you. The information that they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services. We do not control these third parties’ tracking technologies or how they may be used. Please note that this Privacy Policy covers only our use of cookies or other technologies and does not describe the use of technologies by any third parties. If you have any questions about an advertisement or other targeted content you receive from a third party, you should contact the responsible provider directly.

For example, we may use Google Analytics tools to collect and analyze information about the use of the App. This information helps us improve our App and services. In addition, some of the information collected via Google Analytics, including your personal information, is shared with other Google websites. Google may use the collected data to contextualize and personalize the ads of its own advertising network and for its own analytics purposes.

You can opt-out of having made your personal information and/or activity on the App available to Google Analytics by managing your advertising settings in your Google account, or installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visit activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page https://policies.google.com/privacy?hl=en.

HOW WE USE YOUR INFORMATION COLLECTED IN THE APP
(a) General Use. In general, we use your personal information collected through your use of the Services to respond to your requests as submitted through the Services, to provide you the Services you request, and to help serve you better. We use your personal information, in connection with the App, in the following ways to:
• facilitate the creation of, and secure and maintain your account;
• identify you as a legitimate user in our system;
• provide improved administration of the Services;
• provide the Services you request;
• improve the quality of experience when you interact with the Services;
• send you administrative e-mail notifications, such as security or support and maintenance advisories; and
• send surveys, offers, and other promotional materials related to the Services.

(b) Compliance and protection. We may use your personal information to:
• comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
(c) Creation of Non-Identifiable Data. The App may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties in our discretion.
(d) Other purposes. We may also use your personal information for any other reason that you may request from us, that we may disclose to you at the time of collection, or for any other purpose with your consent or as provided in accordance with applicable law and/or regulations.


DISCLOSURE OF YOUR PERSONAL INFORMATION
We disclose your personal information collected through your use of the Services as described below.
(a) In Accordance with Our Other Privacy Notices. Other than as described in this Privacy Policy in connection with the App, this Privacy Policy does not apply to the processing of your information by us or third parties with whom we share information.
(b) Third Party Service Providers. We may share your personal information with third party or affiliated service providers that perform services for or on behalf of us in providing the App, for the purposes described in this Privacy Policy, including, to provide you with the Services; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the Services; to provide technical support; and/or to provide other services to the App.
(c) Authorities and Others. Regardless of any choices you make regarding your personal information, the App may disclose your personal information to law enforcement, government authorities, and private parties, for the compliance and protection services described above. We may also disclose your personal information to others as required to enforce our agreements, contracts, or other legal documents with you, and/or if we believe it is necessary or appropriate to do so to protect the rights, property, or safety of Sidney, our members, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us in response to our other Privacy Notices.

LINKS TO OTHER SITES
The App may contain links to third party websites. When you click on a link to any other website or location, you will leave the App and go to another site and another entity may collect personal and/or anonymous information from you. The App’s provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot and will not be responsible or liable for, these outside websites or their content. Sidney expressly disclaims all liability for damages or losses of any kind whatsoever arising out of, in connection with, related to and/or resulting from use of, reference to, or reliance on any services or information provided by these outside websites or their content. Sidney makes no warranty, express or implied, regarding any services or information provided by these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites. We encourage you to read the privacy policy of every website you visit.

YOUR CHOICES REGARDING YOUR INFORMATION
You have several choices regarding use of information on the Services.
(a) How We Respond to Do Not Track Signals. Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise this Policy regarding responding to these signals.
(b) Cookies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the App may then be inaccessible or not function properly.
(c) Access, Update, or Correct Your Information. You can access, update, or correct your information by changing preferences in your account. For additional requests, please contact us.
(d) Opting Out of Email or SMS Communications. If you have signed-up to receive our email marketing communications, you can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information under “Contact Us” below. This opt-out does not apply to communications sent by Sidney for our everyday business purposes, such as to process your transactions, maintain your accounts, respond to court orders and legal investigations, or report to credit bureaus as described in our other Privacy Notices. If you provide your phone number through the Services, we may send you notifications by SMS, such as to provide a fraud alert. We may provide marketing communications via SMS communications. If you opt-in to our SMS marketing communications, you may opt-out at any time in accordance with the applicable SMS policy. Please review any policy that we may make available to you for more details.
(e) Opting Out of Location Tracking. If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the App.

SAFEGUARDS AND RETENTION
We implement commercially reasonable administrative, technical, and physical measures designed to safeguard the information in our custody and control to reduce the risk of theft, loss and unauthorized access, use, modification and disclosure. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information. While we strive to use commercially reasonable means to protect your information, we cannot guarantee its absolute security.

A NOTE ABOUT CHILDREN
The Services are not directed towards individuals under the age of 13, and we do not, through the App, intentionally gather personal information about visitors who are under the age of 13. If a child under 13 directly submits personal information to us through the App and we learn that the personal information is the information of a child under 13 without parental consent, we will attempt to delete the information as soon as possible. If you believe we might have any information from or about a child under 13, please contact us at cuonline@sidneyfcu.org.

PRIVACY POLICY UPDATES
This Privacy Policy is subject to occasional revision. We will notify you of any material changes in the collection, use, or disclosure of your personal information by mail and/or a prominent notice on the App or via another means, and we will update the “Last Modified” date at the top of the Policy. Any material changes to this Privacy Policy will be effective thirty (30) calendar days following notice of the changes on the Services. These changes will be effective immediately for new users of the Services. If you object to any such changes, you must notify us prior to the effective date of such changes that you wish to deactivate your account. Continued use of the Services following notice of any such changes shall indicate your acceptance of and agreement with such changes.

CONTACT US
If you have any questions or complaints about this Privacy Policy or the App’s data collection or processing practices, or if you want to report any security violations to the App, please contact the App by email at: cuonline@sidneyfcu.org; or by mail at:
Sidney Federal Credit Union
42 Union Street
Sidney, NY 13838
Attn: Stacey Flanagan