INOVA Federal Credit Union
Online Privacy Policy
Introduction and Intention
INOVA Federal Credit Union, together with its subsidiaries and affiliates (collectively, “INOVA Federal”, “we”, “us” or “our”), strives to serve your needs and to protect your identity and any information we collect about you.
Online and Mobile Privacy Notice
Your privacy is important to us. This Online Privacy Notice (the “Notice”) describes how information is collected by and through websites, digital banking, and other online interfaces or platforms that are owned, operated, or controlled by INOVA Federal or its affiliated companies (collectively, the “Sites”), including this Site, and how that information may be used and shared.
By accessing or using any Site, you confirm your consent and agreement to the terms of this Notice as may be in effect at that time.
For purposes of this Notice, the terms “we”, “us”, and “our” refer to INOVA Federal that owns, operates, or controls the Site that you use, and such terms may also refer to contractors and service providers engaged by the Credit Union to support their business activities, as the context may require. The terms “you”, “your” and “yours” refer to any person who accesses or uses a Site.
This Notice supplements, but does not replace, the general Website Terms of Use for the use of this Site. In the event of a conflict between the terms of this Notice and the terms of the general Website Terms of Use, the terms of this Notice will govern and control with respect to the matters addressed in this Notice. Certain sites may have separate privacy notices or terms and conditions that are specific to those sites, and when you use or access those sites those separate privacy notices or terms and conditions will apply and will control with respect to the matters addressed therein in the event of a conflict with the terms of this Notice.
With regard to persons who use or obtain our products and services for their own personal, family, or household purposes, this Notice also supplements, but does not replace, and should be read in conjunction with the INOVA Federal Privacy Notice. To the extent that any information at issue is “nonpublic personal information” as defined by Title V of the Gramm-Leach-Bliley Act (Public Law No. 106-102) and applicable related regulations, the INOVA Federal Privacy Notice will apply and control in the event of a conflict with the terms of this Notice, subject to the requirements and provisions of applicable law.
Personal Information We Collect Through Our Sites
Personal information collected through our Sites will depend on how you interact with us and includes information you provide directly when completing forms or transacting with us, such as your name, your home address, your email address, your telephone number, your social security number, your account number, your user ID and password or PIN, transaction information, documents or images, and information from your computer and mobile device where allowed by individual browsers and/or operating systems, such as: unique device identifiers, language, communications data, and responses to advertisements. We also collect information that you do not provide directly, such as information about your device (including, but not limited to, behavioral biometrics relating to your use of your device for identity verification, fraud avoidance, and security purposes) or internet browser, information obtained from cookies that have been placed on your device or internet browser at our Sites or at other websites you have visited, demographic information, aggregated information, blind information about how you use our products and services and about the transactions you perform using our products and services, and other information obtained through your access to or use of a Site. We may supplement the information we collect from you with information we receive about you from other sources.
How Do We Use Information That We Collect?
We collect personal information when you use our Sites to apply for, obtain, or use our products and services, to make inquiries about our products and services, or to provide information and feedback about our products and services. In connection with your use of our Sites, products, and services, we may ask for, and you may provide, personal information in forms, surveys, applications, and online fields, or you may authorize us to collect personal information from third party sources. We may use personal information and share it with our service providers:
- To respond to your inquiries and requests, and to send you notifications.
- To send administrative information to you, such as information regarding the Site and changes to our terms, conditions and policies.
- To complete and fulfill your applications for our products and services and to deliver and perform such products and services, to execute inquiries and transactions you have requested, to communicate with you regarding products and services you have obtained from us, and to provide you with related customer service.
- To verify your identity or location for security purposes.
- To send you marketing communications that we believe may be of interest to you and otherwise for advertising and sales purposes, whether online or through offline channels like branches, call centers, and direct marketing (for example email, mail, and phone).
- To personalize your experience on the Site by presenting products and offers tailored to you.
- As you agree, authorize, or consent in agreements, terms, and conditions you agree to or accept in connection with products and services you obtain from us.
- For our business purposes, including (but not limited to) such purposes as (i) data analysis, (ii) audits, (iii) fraud monitoring and prevention, (iv) new product development, (v) enhancing, improving or modifying our products and services, (vi) identifying usage trends, (vii) determining the effectiveness of our promotional campaigns, and (viii) operating and expanding our business activities.
- As we believe to be necessary or appropriate (i) under applicable law, (ii) to comply with legal process and otherwise to comply with applicable laws, rules, and regulations, (iii) to respond to lawful requests from public and government authorities, (iv) to enforce our terms and conditions, (v) to protect our operations or those of any of our affiliates, (vi) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others, and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
- For additional information about how we collect, use, share, and protect personal information about our consumer customers, and for information about the choices you may have, please review the INOVA Federal Privacy Notice.
Keeping Your Information Accurate
It is important that we have accurate and up-to-date information about you. If you notice that your information is incomplete, inaccurate, or out of date, you can update your information through our mobile or online banking or by contacting us at 1-800-645-3732. You may also write to us at INOVA Federal Credit Union, PO Box 1148, Elkhart, IN 46515-1148.
How We Collect, Use and Share Personal and Other Information You Do Not Provide to Us Directly
We may collect information you do not provide to us directly:
- Through or from your device or browser or cookies that have been placed on your browser. Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version and internet browser type and version. We use this information to ensure that the Sites function properly and to maintain security.
- Using pixel tags and similar technologies. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Site pages and HTML-formatted email messages in order to, among other functions, track the actions of users and email recipients, measure the success of our marketing campaigns and compile statistics about Site use and response rates.
- Using your IP address. Your IP address is a number that is automatically assigned by your internet service provider to the computer or device that you are using. An IP address is identified and logged automatically in our server log files whenever a user visits a Site, along with the time of the visit and the pages that were visited. We use IP addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Sites.
- Using geolocation and other location information transmitted by your device, if you have enabled location services on the device, and
- Using behavioral biometrics relating to your use of your device for identity verification, fraud avoidance, and security purposes.
We may use, disclose, and share information you do not provide to us directly as described in this Notice (including using and sharing such information with our service providers for the purpose of sending you marketing communications that we believe may be of interest to you and otherwise for advertising and sales purposes, whether online or through offline channels like branches, call centers, and direct marketing (for example, email, mail, and phone)) or as otherwise permitted or required by applicable law.
Types of tracking technologies used
- We use cookies, JavaScript, and similar technologies. Among these technologies, we employ a software technology called clear gifs (or web beacons), that help us better manage the advertising content on our network of third-party sites. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online activities of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. In compliance with the Network Advertising Initiative (NAI) Code of Conduct, we do not tie the device identifying information gathered by clear gifs to personally identifiable information except as permitted by the NAI Code.
Specific data collected
- Physical addresses
- Consumer characteristics such as demographics and predicted interests.
- User activities on non-affiliated websites, mobile apps, online services, and connected TVs.
- Device and visit information, including:
- Browser type and version.
- Internet service provider (ISP).
- Mobile operating system.
- Referring/exit pages.
- Operating system.
- Date/time stamp.
- Ad responses and clickstream data.
- IP addresses.
- Mobile advertising identifiers.
- Cookie identifiers.
- Data made available through third-party mobile apps or web pages.
- Received from third-party partners.
How that data is shared with third parties
- Information is shared with third-party vendors who provide services on our behalf.
- We may also disclose any information if required to do so by law or in the good faith belief that such action is necessary to: (1) comply with legal process, (2) protect and defend our rights or property; (3) protect the personal safety of users; (4) provide updates and services that may be of interest to the user; or (5) prevent online fraud or other cyber threats, for example through an online threat exchange, or to report, detect and/or prevent security events.
- Our third-party partners are required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Our third-party partners may disclose Personal Information with notice or with your consent, where permitted by law.
The purpose of data collection
- The collection of this data about your online activities across non-affiliated properties and linked devices allows us and our 3rd party partners to better target advertising to user interests. This process is called interest-based advertising. The Advertising Services include various analytics and measurement services as well. The data also allows us to improve our services, for example, improving the effectiveness of the advertisements delivered to users and limiting the number of times a person sees a given advertisement.
User rights and options for opting out or managing preferences.
- If members would like to stop receiving interest-based advertising on their browser, they can do so by clicking here. By doing so, Simplifi will replace their unique cookie with an “opt-out” flag that will prevent them from serving the member interest-based advertising. An opt-out choice means that Simplifi no longer uses or transfers data from the opted-out device for targeted advertisements, and they no longer use data collected on other devices to inform advertisements on that device. Simplifi will still collect and store information through such cookies for other purposes such as metrics and analytics and we may still serve advertising, but it will not be tailored for the member. Because cookies are browser specific, if members use more than one browser or device, they will need to opt-out on each browser or device that they use. Please note that they will need to set the Simplifi opt-out cookie again in some cases, for example, under the following circumstances: they buy a new computer or device, delete cookies from your browser, or upgrade or change the browser of their existing computer or device.
Social Media
INOVA Federal maintains social media sites, including but not limited to Facebook®, Instagram®, LinkedIn®, and YouTube® and may interact with registered users of these sites. Any content you post to these sites (including pictures, information, or opinions) as well as information you make available on these sites is subject to the applicable site’s terms of use and privacy notice. Please review the privacy policy for the specific social media service you are using to better understand your rights and obligations regarding such content.
Children’s Online Privacy
Online financial services that are offered through INOVA Federal’s website are not designed for or directed toward children under the age of 13. We do not knowingly collect information from children under 13 without parental consent. We encourage parents or guardians to monitor children under 13 when the children are online and to participate in any interactive activities offered on the website.
Linking to Third Party Websites
INOVA Federal Credit Union may provide links to websites that are owned or operated by other companies ("third-party websites"). When you use a link online to visit a third-party website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use, and security practices of the linked third-party website before providing any information on that website.
Information Security Standards
INOVA Federal continually updates and improves our security standards and procedures to prevent fraud and help protect against anyone gaining unauthorized access to your confidential information. We maintain physical, electronic and procedural safeguards that comply with federal standards. Our employees have an appropriate level of access to your personal information to perform their jobs and provide you with the best financial products and services possible. We work with law enforcement officials to pursue any individuals who either fraudulently access or attempt to access or use information. We are continually looking for new technology to further enhance the security of this information through appropriate checks and balances built into procedures.
Changes to this Notice
We reserve the right to amend this Policy at any time to address future developments or changes in industry or legal trends. We will post the revised Policy on our Sites. If we make changes to this Policy, we will revise the "Effective Date" section above. Any changes to this Policy will become effective upon the posting of the revised Policy on our Sites. By continuing to use our Sites following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or in part, please do not continue using our Sites.
Questions about this Notice
If you have questions or require additional information regarding our privacy practices, please contact us at (800) 645-3732.
INOVA Federal Credit Union
Privacy Policy
| FACTS |
WHAT DOES INOVA FEDERAL CREDIT UNION DO WITH YOUR PERSONAL INFORMATION? |
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| Why? |
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
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| What? |
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
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| How? |
All financial companies need to share members' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their members' personal information; the reasons INOVA Federal Credit Union chooses to share; and whether you can limit this sharing. |
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| Reasons we can share your personal information | Does INOVA Federal Credit Union share? | Can you limit this sharing? |
|---|---|---|
| For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus |
Yes | No |
| For our marketing purposes – to offer our products and services to you |
Yes | No |
| For joint marketing with other financial companies | Yes | No |
| For our affiliates' everyday business purposes – information about your transactions and experiences |
No | We don't share |
| For our affiliates' everyday business purposes – information about your creditworthiness |
No | We don't share |
| For our affiliates to market to you | Yes | Yes |
| For nonaffiliates to market to you | No | We don't share |
| TO LIMIT OUR SHARING |
Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. |
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| Questions? | Call toll-free (800) 645-3732 or go to inovafederal.org |
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| What We Do | |
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| How does INOVA Federal Credit Union protect my personal information? |
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. |
| How does INOVA Federal Credit Union collect my personal information? |
We collect your personal information, for example, when you
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies. |
| Why can't I limit all sharing? |
Federal law gives you the right to limit only:
State laws and individual companies may give you additional rights to limit sharing. |
| What happens when I limit sharing for an account I hold jointly with someone else? |
Your choices will apply to everyone on your account. |
| Definitions | |
|---|---|
| Affiliates |
Companies related by common ownership or control. They can be financial and nonfinancial companies.
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| Nonaffiliates |
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
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| Joint Marketing |
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
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