CCPA PRIVACY POLICY FOR CALIFORNIA RESIDENTS
Rev. 03/01/2026
This CCPA Privacy Policy for California Residents (“CCPA Privacy Policy”) supplements the information contained in Credit Union of Southern California, a Federal Credit Union’s (“we”, “us” and “CU SoCal”) Online Privacy Policy (https://wwwstg.cusocal.org/legal/privacy-policy/) and applies solely to all visitors, users, and others, as well as owners, directors, officers and employees of companies that do business with CU SoCal, who reside in the State of California (“consumers” or “you”). We adopt this policy to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (CCPA), and its implementing regulations, and any terms defined in the CCPA have the same meaning when used in this Policy.
This CCPA Privacy Policy explains how we collect, share, use, and protect your personal information through your online and offline interactions with us. As used in this CCPA Privacy Policy, “personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
The specific personal information that we collect, use, and disclose relating to a California resident in different contexts covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this CCPA Privacy Policy does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for personal, family, or household purposes (i.e., information subject to the GLBA). For more information about how we collect, disclose, and secure information relating to these customers, please refer to our Federal Privacy Notice.
In the preceding 12-months, we have collected the following categories of personal information (please note that some categories overlap):
| Category | Examples |
|---|---|
| A. Identifiers | A real name or alias; postal address; signature; home phone number or mobile phone number; membership number, credit card number, debit card number, or other financial information; physical characteristics or description; email address; account name; Social Security number; driver’s license number or state identification card number; passport number; or other similar identifiers. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A 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 history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
| C. Protected classification characteristics under state or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
| D. Commercial information | Records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies. |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
| F. Internet or other similar network activity | Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement. |
| G. Geolocation data | Physical location or movements. For example, city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and, with your permission in accordance with your mobile device settings, precise geolocation information from GPS-based functionality on your mobile devices. |
| H. Sensory data | Audio, electronic, visual, or similar information. |
| I. Professional or employment-related information | Current or past job history, performance evaluations, disciplinary records, workplace injury records, disability accommodations, and complaint records; Emergency contact information, such as the name, phone number, address and email address of another person in the context of having an emergency contact on file; Personal information necessary for us to collect and retain to administer benefits for you and another personal relating to you (e.g., your spouse, domestic partner, and dependents), such as their name, Social Security Number, date of birth, telephone number, email, and address. |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Educational records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preference, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
| L. Sensitive Personal Information | 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, and text messages unless the business is the intended recipient of the communication; A consumer’s genetic data; A consumer’s neural data; The processing of biometric information for the purpose of uniquely identifying a consumer; Personal information collected and analyzed concerning a consumer’s health; Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation; and immigration or citizenship status. |
For purposes of the CCPA, “personal information” does not include:
- Publicly available information.
- De-identified information that cannot reasonably be used to identify you or your household.
- Aggregated consumer information that relates to a group or category of consumers, from which consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device.
- Information excluded from the CCPA’s scope like personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from consumers or their agents. For example, from forms you complete, when you perform transactions, and when you purchase products or services.
- Indirectly from consumers or their agents. For example, when you use your debit or credit cards, when you make deposits or withdrawals to/from your accounts, or when you pay your bills.
- Directly and indirectly from activity on our website or our mobile applications. For example, from submissions through our website, application portals, or website usage collected automatically.
- From third parties, such as credit reporting agencies, government agencies, law enforcement agencies, and service providers.
We may use or disclose personal information we collect for one or more of the following operational or other notified purposes (“business purposes”):
- To fulfill or meet the reason for which the information is provided. For example, if you apply for a loan, we use the information in your loan application to evaluate your credit request and grant you the loan if approved.
- To provide you with information, products, or services that you request from us.
- To provide you with email alerts, event registrations, or other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, and analysis to improve our products and services and for developing new ones.
- To protect the rights, property, or safety of us, our employees, our members, or others.
- To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us is among the assets transferred.
- As otherwise permitted under law.
With respect to your personal information that is deemed “sensitive personal information” under the CCPA, we do not use or disclose it for any purpose other than, as reasonably necessary and proportionate, for the following purposes:
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods and services.
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
- To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
- To ensure the physical safety of natural persons.
- For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside of your current interaction with us.
- For our service providers or contractors to perform services on our behalf, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf; provided, however, that the use of your sensitive personal information is reasonably necessary and proportionate for this purpose.
- To verify or maintain the quality or safety of a service or device that is owned, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured for, or controlled by us; provided, however, that the use of your sensitive personal information is reasonably necessary and proportionate for this purpose.
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about you.
Any sensitive personal information we collect about you is used or disclosed only for the purposes set forth in Section 7027(m) of the California Code of Regulations and not for inferring characteristics about.
In addition to the specific situations discussed elsewhere in this CCPA Privacy Policy, we may disclose your personal information in the following situations:
- Service Providers. We may provide your information to service providers. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, process payments, assist in the fulfillment of services, and help us market our own products and services.
- Joint Marketing Partners. We may provide your information to other companies to offer you co-branded financial products and services.
- Advertising Networks. We may provide your information to advertising networks such as Google and Facebook to help us deliver our advertisements to you as you are browsing online.
- Compliance with Laws and Other Lawful Uses. We may disclose information to law enforcement agencies and other government entities or private parties in litigation in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also provide your information to these parties to establish or exercise our rights, to defend against a claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies. We may also disclose your personal information to our acquisition or merger partners in the event of an acquisition or merger. Furthermore, we may disclose your personal information as permitted by applicable law. All of the categories of personal information we collect from you may be disclosed for this purpose.
- Your Consent. All the categories of personal information we collect from you may be disclosed to third parties with your consent or direction.
In addition to the information above, the table below indicates the specific categories of personal information defined in the CCPA that have been disclosed to third parties for a “business purpose,” or “sold” (or transferred for “valuable consideration”), or “shared” for purposes of cross-context behavioral advertising.
| CATEGORY OF PERSONAL INFORMATION | CATEGORY OF RECIPIENTS (FOR BUSINESS PURPOSE) | CATEGORY OF RECIPIENTS (FOR “SALE” OR “VALUABLE CONSIDERATION” | CATEGORY OF RECIPIENTS (CROSS-CONTEXT BEHAVIORAL ADVERTISING) |
|---|---|---|---|
| Identifiers such as name, address, unique personal identifier, email address, or account name. | Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent. |
Not sold. | Not shared. |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent. |
Not sold. | Not shared. |
| Protected classification characteristics under state or federal law | Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent. |
Not sold. | Not shared. |
| Commercial information | Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent. |
Not sold. | Not shared. |
| Biometric information | Service providers; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent. |
Not sold. | Not shared. |
| Internet or other similar network activity | Service providers; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent |
Not sold. | Not shared. |
| Geolocation data | Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent. |
Not sold. | Not shared. |
| Sensory data | Service providers; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent. |
Not sold. | Not shared. |
| Professional or employment-related information | Service providers; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent. |
Not sold. | Not shared. |
| Non-public education information | Service providers; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent. |
Not sold. | Not shared. |
| Inferences drawn from other personal information | Service providers; Joint marketing partners; Advertising networks; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent. |
Not sold. | Not shared. |
| Sensitive personal information | Service providers; Third parties for compliance with laws and other lawful purposes; and Third parties with your consent. |
Not sold. | Not shared |
This section describes your rights and choices regarding how we collect, share, use, and protect your personal information, how to exercise those rights, and limits and exceptions to your rights and choices.
- If you are not a California resident;
- If we collected personal information covered by certain financial sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”) and/or California Financial Information Privacy Act (“CFIPA”). How we collect, share, use, and protect your personal information is covered under such laws instead of the CCPA; or
- To aggregate consumer information; or
- To deidentified personal information; or
- Publicly available personal information.
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting, sharing or selling that personal information, as applicable.
- The categories of third parties to whom we disclosed, shared or sold the personal information, as applicable.
- The specific pieces of personal information we collected about you in a form that you can take with you (also called a “data portability request”).
To exercise the rights described above, you or your authorized agent may submit a verifiable consumer request to us by any of the following methods:
- Calling 866 CU SoCal (866.287.6225).
- Submitting a Form below under the “Your privacy Rights” section.
When we receive a verifiable request from your authorized agent we may require:
We will not require either of the above if the authorized agent provides a copy of a power of attorney pursuant to California Probate Code sections 4121 to 4130 and we are able to verify the authorized agent’s identity.
We will deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf and cannot verify their own identity to us.
We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response to the mailing address of record according to our files. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hinderance.
The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request.
We will not discriminate against you for exercising any of your rights in this Disclosure and under applicable laws. Unless permitted by law, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price for goods or services or a different level or quality of goods or services.
It is not our policy to sell personal information or share it with third parties for cross-context behavioral advertising, and we have not done so in the last 12-month period. Therefore, we are not required to provide you with the right to opt-out of sale or sharing.
We only use a consumer’s sensitive personal information for the purposes identified in Section 7027(m) of the California Code of Regulations. Therefore, we are not required to give you notice of the right to limit the use of sensitive personal information or give you the opportunity to request that such information be limited.
The credit union does not knowingly collect or maintain information on children under the age of 13 unless they are a party to an account including an owner or co-owner, a beneficiary, or under a Uniform Transfers to Minor’s Act or Coogan Account. Moreover, the credit union does not knowingly sell or share the personal information about consumers under age 16.
We reserve the right to amend this CCPA Privacy Policy at our discretion and at any time. When we do so, we will post an updated CCPA Privacy Policy on our website and mobile application.
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights, call 866 CU SoCal (866.287.6225), email us at [email protected] or mail us at Credit Union of Southern California, Attn: Privacy Department, 8101 E. Kaiser Blvd, Suite 300, Anaheim, CA 92808.
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