CALIFORNIA CONSUMER PRIVACY ACT (CCPA) DISCLOSURE & NOTICE AT COLLECTION

If you are a California resident, this disclosure applies to you. Certain terms used in this disclosure have defined meanings as set out in the California Consumer Privacy Act. This CCPA Disclosure includes information about the personal information Liberty Federal Credit Union (collectively “Liberty FCU”, “our”, “we”) collect about our members (“you”) and the rights granted to members who are California residents under the CCPA.

Categories of Personal Information Liberty FCU has collected from its Members in the preceding 12 months

• Personal identifiers, including name, alias, mailing address, postal address, email address, Social Security number, driver’s license number, other government issued number, telephone number, online or device identifier, IP address
• Characteristics of protected classifications, including age, gender, military or veteran status, marital status, nationality, citizenship
• Financial information, including bank account numbers, debit or credit card numbers, cardholder or accountholder name and information, transactions details, loan requests, collateral information
• Biometric information
• Commercial information
• Internet or other electronic network activity
• Geolocation data
• Audio, electronic, visual, or similar information, including communications, recordings, images
• Inferences drawn from any of the above
• Employment-related information
• Commercial information, including records of personal property, products or services purchased or considered
• Inferences or assumptions derived from the above-listed categories used to create a profile about a consumer reflecting characteristics, behavior, preferences, attitudes, intelligence, abilities

Categories of Sources from which Liberty FCU has collected Personal Information

• From you when you provide it to us via telephone, email, in-person, or by other methods
• Social media, only personal information which is made publicly available to view
• Third parties who provide it to us, including credit reporting agencies, law enforcement authorities, other members
• When you visit our website or use our mobile banking application, including device type, operating system, browser type and settings, IP address, language settings, dates and times of connection to the website or mobile application

Business or Commercial purposes for use of Personal Information

• Marketing and internal research
• Performing internal account and loan origination and servicing services
• Auditing
• Operating and maintenance of our websites and mobile application
• IT Operations
• Physical and cyber security
• Investigations and legal proceedings
• Regulatory and legal compliance
• Risk Management, including compliance, internal audit
• Fraud prevention

Categories of Third Parties to Whom Personal Information is Disclosed

• You and your family or household members, joint owners, and representatives, as applicable
• Local, state, and federal government, legal, regulatory, and other similar authorities where required
• Anti-fraud services
• External regulators and examiners
• Third-party professionals, such as accountants, lawyers, auditors, etc.
• Third- party service providers, such as payment processing providers, corporate credit unions, etc.
• Applicable relevant third-party acquirers, in the event that we sell or transfer all or any portion of our assets

Sale of Personal Information

Liberty FCU does not sell your personal information as determined under the CCPA.

Non-Discrimination

Liberty FCU will not discriminate against you because you exercise your privacy rights under the CCPA.

Under the CCPA, you have the following rights:

• The right to request Liberty FCU disclose to you:
  • Categories of personal information (PI) we collected about you during the preceding 12 months
  • Categories of sources from which PI is collected
  • Business or commercial purposes for collecting PI
  • Categories of PI, if any, that we have disclosed for a business purpose to third parties in the preceding 12 months
  • Categories of third parties to whom the PI was shared
• The right to request deletion of PI we collected from you
• The right to have someone you authorize make a request on your behalf (See below for direction)

Requests by Authorized Agent

An authorized agent may submit a request for disclosure of PI or a request to delete PI on your behalf. In order to protect your PI, we must obtain your signed permission granting your authorized agent the authority to make an applicable request on your behalf.

If your authorized agent is making a request on your behalf under a Power of Attorney, the Power of Attorney document must be submitted with the request. You, or your authorized agent, can make a request at the links in the section below titled “To submit a request”.

If your authorized agent is making a request on your behalf not under a Power of Attorney, when your authorized agent makes a request on your behalf, they must fill out and upload the document titled “CCPA Authorized Agent Designation Form” available for download in the online request form. The CCPA Authorized Agent Designation Form includes a statement granting authority to your authorized agent to make a request to disclose PI or a request to delete PI on your behalf. This document must be signed by you. We may require you and your authorized agent to verify your identities.

To submit a request:

Note- we will only respond to two requests made by you or your authorized agent in a 12-month period, as permitted under the CCPA

• Disclosure requests can be made by calling 1-800-800-9271 or click online at https://libertyfcu.org/ccpa-request
• Deletion requests can be made by calling 1-800-800-9271 or online at https://libertyfcu.org/ccpa-request

There are some situations where we will not, or may not be able to, comply with some or all of your request:

• If you are not a California resident
• If we cannot verify your identity
• If we are required or permitted under federal laws and regulations to maintain your personal information
• If you or your authorized agent have already submitted two requests in a 12-month period

When you or your authorized agent submit a request to know or a request to delete, you must include certain identifying information including your first and last name, email address, phone number, and address. We will compare the information you provide with your request to the information we maintain to verify your identity. If we cannot verify your identity, we may deny your request or ask you for additional information.

For more information, contact ccpa@libertyfcu.org

This CCPA Disclosure was last updated August 2022.