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Envision Credit Union  Mobile and Digital Banking Privacy Policy

Last updated June 10, 2024

Federal law requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand how we handle user privacy.
Envision Credit Union (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our mobile application (the “Application”) or when the app is not in use. Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATION.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted.
This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.

COLLECTION OF YOUR INFORMATION
We may collect information about you in a variety of ways. The information we may collect via the Application depends on the content and materials you use and includes:

Personal Data
Demographic and other personally identifiable information (such as your name and email address) that you voluntarily give to or share with us when using the app or any related services.   

Derivative Data
Information our servers automatically collect when you access the Application, such as your native actions that are integral to the Application, as well as other interactions with the Application via server log files.

Geo-Location Information
We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access
We may request access or permission to certain features from your mobile device, including your mobile device’s location services. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data
Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.

Push Notifications
We may request to send you push notifications regarding your account or the Application. If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. We may use information collected about you via the Application to, among other things:
●      Assist law enforcement and respond to subpoena.
●      Compile anonymous statistical data and analysis for use internally or with third parties.
●      Create and manage your account.
●      Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and our mobile application to you.
●      Email you regarding your account or order.
●      Enable user-to-user communications.
●      Fulfill and manage purchases, orders, payments, and other transactions related to the mobile application.
●      Generate a personal profile about you to make future visits to the mobile application more personalized.
●      Increase the efficiency and operation of our mobile application.
●      Monitor and analyze usage and trends to improve your experience with our mobile application.
●      Notify you of updates to the mobile application.
●      Perform other business activities as needed.
●      Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
●      Process payments and refunds.
●      Request feedback and contact you about your use of our mobile application.
●      Resolve disputes and troubleshoot problems.
●      Respond to product and customer service requests.
●      Solicit support for the mobile application.

DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers
We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Marketing Communications
With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

Third-Party Advertisers
We may use third-party advertising companies to serve ads when you visit the Application. These companies may use information about your visits to the Application and other websites that are contained in web cookies in order to provide advertisements about goods and services of interest to you.

Affiliates
We may share your information with our affiliates, in which case we will require those affiliates to honor this Mobile App Privacy Policy. Affiliates include any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Sale or Bankruptcy
If we undergo a merger or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy or conservatorship, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline to honor commitments we made in this Privacy Policy.
We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations.  If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

TRACKING TECHNOLOGIES

Cookies and Web Beacons
We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Application to help customize the Application and improve your experience. When you access the Application, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies but be aware that such action could affect the availability and functionality of the Application. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

Internet-Based Advertising
Additionally, we may use third-party software to serve ads on the Application. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us. For more information about opting out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

Website Analytics
We may also partner with selected third-party vendors, such as Google Analytics, to allow tracking technologies and remarketing services on the Application through the use of first-party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Application, determine the popularity of certain content, and better understand online activity. By accessing the Application, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors.
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

THIRD-PARTY WEBSITES
The Application may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Application, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third-party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services, or applications that may be linked to or from the Application.

SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information and are not responsible for any interception or misuse by unauthorized parties unless otherwise provided for by applicable law.

ZELLE INFORMATION COLLECTED
Zelle is a convenient way to send money to friends, family, and others you trust. When you use Zelle through our mobile banking app, we may collect and share the following information with Zelle’s service providers and the recipient’s financial institution:

Personal Information
Zelle may collect /transmit/sync/stores information about your name, email address, ssn, mobile phone number. This information is necessary to process your transaction securely and efficiently.

Financial Information
Zelle may collect /transmit/sync/store information about your transaction, this includes debit cards linked to Zelle
account, bank account numbers, and transaction history made through the app, including Zelle transactions.

Transaction Data
Zelle stores information about the transaction you make using their services. This includes details such as the amount sent or received, the recipient’s information and the timestamp of the transaction.

Upload Contact List Information
With your explicit consent, Zelle may collect /transmit/sync/store/ access and upload your contact list information to facilitate the Zelle service. This includes contact names, address, phone numbers, and email addresses.

Device Information
Zelle may collect /transmit/sync/store data about the devices you use to access their service. This can include device identifiers, IP addresses, browser types and operating systems. This information helps ensuring security and providing a personalized user experience. Zelle may collect data about the device you use to access their service. This can include device identifiers, IP address, and browser types.

Location Information
If you enable location services on your device, Zelle may collect /transmit/sync/store data about your location. This can be used for fraud prevention and to offer location-based services.

Cookies and Tracking Technologies
Like many online services, Zelle may collect /transmit/sync/store cookies and other tracking technologies to gather information about browser behaviors and preferences. This helps in improving their services and targeting advertisements.

Communication Data
Zelle may collect /transmit/sync/store information from user’s communications with their customer support team.   Personal Information Collected from Third Parties. We may collect certain information from identity verification services and consumer reporting agencies, including credit bureaus, to provide some of our Services. Check Deposited Images. Zelle may collect /transmit/sync/store check deposit information when users are using the mobile banking app to deposit a check by capturing an image of the front and back of the check that you capture using the mobile app’s camera. The following information may be captured: Payee name, amount, account number and routing number. 

BIOMETRIC INFORMATION PRIVACY POLICY AND CONSENT

Scope and Overview
This policy outlines how Envision Credit Union, its vendors, and/or the licensor of Envision Credit Union’s consumer verification software processes biometric data collected from you for identity verification and fraud prevention purposes.
Biometric Data Defined
As used in this policy, biometric data includes “biometric identifiers” and “biometric information”. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. As the term is used in this policy, the selfie photograph you upload to the software for use in the biometric algorithm is considered a “biometric identifier.” “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.

Disclosure and Authorization Policy
To the extent Envision Credit Union, its vendors, and/or the licensor of Envision Credit Union’s consumer verification software collect, capture, or otherwise obtain biometric data relating to a consumer, Envision Credit Union must first:

• Inform each consumer Envision Credit Union, its vendors, and/or the licensor of Envision Credit Union’s consumer verification software are collecting, capturing, or otherwise obtaining the consumer’s biometric data, and Envision Credit Union is providing such biometric data to its vendors and the licensor of Envision Credit Union’s consumer verification software;

• Inform the consumer of the specific purpose and length of time for which the consumer’s biometric data is being collected, stored, and used; and

• Receive consent by the consumer authorizing Envision Credit Union, its vendors, and/or Envision Credit Union’s consumer verification software to collect, store, and use the consumer’s biometric data for the specific purposes disclosed by Envision Credit Union, and for Envision Credit Union to provide such biometric data to its vendors and the licensor of Envision Credit Union’s consumer verification software.

• Envision Credit Union, its vendors, and/or the licensor of Envision Credit Union’s consumer verification software will not sell, lease, trade, or otherwise profit from consumer’s biometric data; provided, however, Envision Credit Union’s vendors and the licensor of Envision Credit Union’s consumer verification software may be paid for products or services used by Envision Credit Union utilizing such biometric data.

This policy is intended to comply with all federal, state, and local laws.

Purpose for the Collection of Biometric Data
Envision Credit Union, its vendors, and/or the licensor of Envision Credit Union’s consumer verification software collect, store, and use biometric data solely for identity verification and fraud prevention purposes.

Disclosure
Envision Credit Union will not disclose or disseminate any biometric data to anyone other than its vendors and the licensor of Envision Credit Union’s consumer verification software providing products and services using biometric data without/unless:

• First obtaining consumer consent to such disclosure or dissemination;

• The disclosed data completes a financial transaction requested or authorized by the consumer;

• Disclosure is required by law or ordinance; or

• Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Security
Envision Credit Union shall use a commercially reasonable standard of care to store, transmit and protect from disclosure any biometric data collected. Such storage, transmission, and protection from disclosure shall be performed in the same manner as or more protective than the manner in which Envision Credit Union stores, transmits and protects from disclosure other confidential and sensitive information, including personal information used to uniquely identify an individual or an individual’s account or property, such as, account numbers, PINs, driver’s license numbers and social security numbers.

Retention
Envision Credit Union shall retain consumer biometric data only until, and shall request its vendors and the licensor of Envision Credit Union’s consumer verification software permanently destroy such data when, the first of the following occurs:
The initial purpose for collecting or obtaining such biometric data has been satisfied, such as verification of consumer identity;
Request of consumer to destroy the biometric data; or
Within 30 days of consumer’s provisioning of biometric data.

Contact Information
If you have any questions about our use, storage, or security of your biometric data you can contact us at: [email protected]

BIOMETRIC INFORMATION CONSUMER CONSENT
As outlined in the “Biometric Information Privacy Policy”, I understand and consent to the collection, use, retention, storage, and/or disclosure or re-disclosure of data or images from biometric verification technology by Envision Credit Union, its vendors, and/or the licensor of Envision Credit Union’s consumer verification software. I acknowledge I have been given a copy of the Policy, or the Policy has been made accessible to me, and I have had an opportunity to review it and request any additional information concerning Envision Credit Union’s procedures and safeguards for collecting, maintaining, using, disclosing, sharing, storing, and/or destroying this data.

POLICY FOR CHILDREN
We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

OPTIONS REGARDING YOUR INFORMATION

Account Information
You may at any time review or change the information in your account through the Application by: 

• Logging into your account settings and updating your account.
• Contacting us using the contact information provided below.

Deleting the app from your phone will not affect your accounts with us.
In addition, please be advised that, if you terminate your account(s) with us, we will deactivate or delete your account(s) and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with legal requirements.
Emails and Communications
If you no longer wish to receive push notifications or in-app ads, you may opt-out by: 

• Noting your preferences at the time you register your account with the Application.
• Logging into your account settings and updating your preferences.

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

YOUR CONSENT
By using our application or interacting with any advertisement on the application or page on a third-party site, you consent to this Mobile App Privacy Policy and our collection, use and disclosure of information about you as described in this Policy.

NOTICE TO PERSONS USING THE APPLICATION FROM OUTSIDE THE UNITIED STATES
If you reside outside of the United States, any information you provide to us on our application will be transferred out of your country and into the United States. If you do not want personally identifiable information to leave your country, do not provide the information to us. By providing personally identifiable information to us, you explicitly consent to the transfer of your information to the United States.

CONTACT US
If you have questions or comments about this Privacy Policy, please contact us at:
Envision Credit Union
PO Box 5198
Tallahassee, FL 32314
(850)-942-9000 or (800)-824-389