KeyPoint Credit Union California Consumer Privacy Act Policy

Last updated: March 1, 2023

KeyPoint Credit Union created this California Consumer Privacy Act Policy (Policy) to demonstrate our firm commitment to consumer privacy.

This Policy discloses our personal information collection and sharing practices for consumers who are covered by the California Consumer Privacy Act. This policy applies to (a) individual consumers associated with Credit Union business accounts or credit (b) individuals who apply for employment with or are employed by Credit Union, or (c) individuals who provide information to Credit Union other than in connection with obtaining Credit Union financial services. This Policy does not apply to individuals who apply for or obtain Credit Union financial services for personal, family, or household purposes.

Your Rights under the California Consumer Privacy Act (CCPA)

The CCPA provides California residents (consumers) with rights regarding your personal information. This Policy describes how you can exercise your rights under the CCPA to request that we: (1) discontinue the sale of any personal information (we never sell personal information); (2) delete personal information that we have collected from you; (3) correct inaccurate personal information; (4) discontinue sharing personal information; and (5) provide certain personal information that we have collected about you, along with related personal information described below.

Personal Information We Collect

The personal information that we collect will depend on your relationship with us. Below are descriptions of the categories of personal information that we have collected about consumers in the preceding 12 months:

• Identifiers such as a real name, alias, postal and physical address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license or state identification card number, passport number, or other similar identifiers.
  • Sold, Shared or Disclosed: Shared and Disclosed
  • Third parties we may share with or disclose to:
    • Service providers who assist us in processing requests for and maintaining your products and services
    • Credit reporting agencies
    • Federal, state, or local government entities
    • Payroll and benefits companies
    • Attorneys
    • Auditors
• 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.
  • Sold, Shared or Disclosed: Shared and Disclosed
  • Third parties we may share with or disclose to:
    • Service providers who assist us in processing requests for and maintaining your products and services
    • Credit reporting agencies
    • federal, state, or local government entities
    • Payroll and benefits companies
    • Attorneys
    • Auditors
• Characteristics of protected classifications under California or federal law. Includes but not limited to race, color, religion, sex, gender, sexual orientation, marital status, medical condition, military or veteran status, national origin, ancestry, disability, genetic information, age, citizenship, primary language, immigration status.
  • Sold, Shared or Disclosed: Shared and Disclosed
  • Third parties we may share with or disclose to:
    • Service providers who assist us in processing requests for and maintaining your products and services
    • Credit reporting agencies
    • Federal, state, or local government entities
    • Payroll and benefits companies
    • Attorneys
    • Auditors
• Biometric information. Includes but not limited to, an individual’s physiological, biological, or behavioral characteristics.
  • Sold, Shared or Disclosed: Shared and Disclosed
  • Third parties we may share with or disclose to:
    • Service providers who assist us in processing requests for and maintaining your products & services
    • Credit reporting agencies
    • Federal, state, or local government entities
    • Payroll and benefits companies
    • Attorneys
    • Auditors
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
  • Sold, Shared or Disclosed: Shared and Disclosed
  • Third parties we may share with or disclose to:
    • Service providers who assist us in processing requests for and maintaining your products and services
    • Credit reporting agencies
    • Federal, state, or local government entities
    • Payroll and benefits companies
    • Attorneys
    • Auditors
• Geolocation data.
  • Sold, Shared or Disclosed: Shared and Disclosed
  • Third parties we may share with or disclose to:
    • Service providers who assist us in processing requests for and maintaining your products and services
    • Credit reporting agencies
    • Federal, state, or local government entities
    • Payroll and benefits companies
    • Attorneys
    • Auditors
• Audio, electronic, visual, or similar information.
  • Sold, Shared or Disclosed: Shared and Disclosed
  • Third parties we may share with or disclose to:
    • Service providers who assist us in processing requests for and maintaining your products and services
    • Credit reporting agencies
    • Federal, state, or local Government entities
    • Payroll and benefits companies
    • Attorneys
    • Auditors
• Professional or employment-related information.
  • Sold, Shared or Disclosed: Shared and Disclosed
  • Third parties we may share with or disclose to:
    • Service providers who assist us in processing requests for and maintaining your products and services
    • Credit reporting agencies
    • Federal, state, or local government entities
    • Payroll and benefits companies
    • Attorneys
    • Auditors

Use of Sensitive Personal Information

We do not use sensitive personal information other than to perform services requested, detect security incidents, prevent fraudulent actions, perform services on behalf of a business such as providing customer service, processing transactions, and providing financial services.

Sensitive personal information means:

• A consumer’s social security, driver’s license, state identification card, or passport number.
• A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
• A consumer’s precise geolocation.
• A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
• The contents of a consumer’s mail, email, chat message and text messages unless the business is the intended recipient of the communication.
• A consumer’s genetic data.

Sources from Which We Collect Personal Information:

• Information you provide to us to:
  • Apply for or open a business account, loan, or other business-related product or service
  • Complete job applications and other employment-related documents
  • Enter sweepstakes or contests, or subscribe to a newsletter or blog
  • Apply for a scholarship
  • Inquire about services
• Credit-reporting agencies
• Third-party verification services
• Internet search engines, including social media, and internal network activity
• Security video
• Public records
• Government entities

Purpose of Collecting Personal Information:

• Verify your identity
• Contact you regarding application status and process
• Maintain security
• Administer payroll and employee benefits
• Assign computers and software programs
• Provide you information on financial products and services
• Maintain your accounts and services
• Assess your qualifications for a business account or loan
• Assess your financial standing with us
• Process your sweepstakes or contest entry
• Manage your blog or newsletter subscriptions
• Process release authorizations
• Process notification alerts
• Monitor and evaluate compliance with equal employment opportunity laws
• Monitor compliance with non-discrimination laws, collect and report information consistent with fair lending laws, assess your qualifications for initial and ongoing employment
• Contact designated individuals in the event of an emergency
• Assess your eligibility for a scholarship

Sharing and Disclosure of Personal Information

We do not share or disclose your personal information except as allowed by law for a business purpose. We share or disclose personal information with service providers who assist us in determining your eligibility for and servicing your financial products and services or for employment. We contractually require these service providers to not sell, share, or use your personal information for any other purposes. We share your personal information with attorneys and auditors for risk analysis and risk mitigation purposes. We may share your personal information with attorneys to evaluate disputes or errors and enforce your legal obligations.

Right to Discontinue the Sale of Your Personal Information

We do not sell the personal information of consumers to any third party, including personal information about consumers under the age of 16 years.

Right to Have Your Information Deleted

You may request deletion of your personal information by contacting us in one of the ways described below. We may deny your deletion request if retaining the personal information is necessary for us or for our service providers to:

• Complete the transaction for which the information was collected.
• Provide a product or service you have requested or reasonably anticipated within the context of our ongoing relationship with you.
• Perform a contract between us and you.
• Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug or identify and repair errors.
• Comply with a legal obligation.
• Otherwise use your information internally, in a lawful manner that is compatible with the context in which you provided the information.

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

As a consumer, you have the right to request that we disclose certain information to you about our collection and use of your personal information.

We will acknowledge your request within 10 business days and will provide the requested information or reply within 45 calendar days of receipt of the request. If we are not able to respond within 45 calendar days, we will notify you and respond within an additional 45 calendar days (for a maximum total of 90 calendar days from the day the request was received). We reserve the right to verify the legitimacy of all requests, using any information you have given us, or any transactional information we have. We are prohibited from providing the following:

• Social security number
• Driver’s license or other government-issued identification number
• Account number
• Account passwords or security questions and answers
• Health insurance or medical identification number
• Biometric information

Right to Correct Inaccurate Personal Information

You have the right to request us to correct inaccurate personal information about you by contacting us in one of the ways below.

Right to Opt-out of Sharing Personal Information or Sensitive Personal Information

You have the right to direct us to not share your personal information with third parties by contacting us in one of the ways below. We may deny your request because we only share personal information of consumers with other businesses or third parties to process requests as directed by the consumer.

If you wish to submit a request for personal information we collect, use, or disclose, contact us using one of the following methods:

• Call us at (888) 255-3637
• Submit your request online kpcu.com/contact
• Mail your request to:

KeyPoint Credit Union
Attn: Privacy Request
2150 Trade Zone Boulevard, Suite 200
San Jose, CA 95131

• Visit any of our branch locations

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

If you submit your request in person, we may ask to see a current government-issued photo ID such as a driver’s license, passport, or military ID. If you make your request by phone, mail, or via our online portal, we may ask for information that allows us to verify your identity by comparing the information you provide against the information in our records.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

You have a right to non-discriminatory treatment by us when you exercise any privacy rights under the CCPA.

Right to Use an Authorized Agent

You may designate an authorized agent to make a request under the CCPA on your behalf. We retain the right to verify the legitimacy of that designation, and to identify both you and the agent. We will identify you with the information you have previously provided to us and with information about your account(s) or transactions.

We cannot respond to an authorized agent’s request or provide personal information if we cannot verify your identity, the identity of the authorized agent or authority to make the request, and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Notification of Changes

We reserve the right to change or update this Policy in the future. When we do, we will post the revised Policy on our website. For questions about this Policy, contact us at (888) 255-3637.