California Privacy Policy
Effective Date: November 1, 2020
Last Updated: November 1, 2022
This Thrivent Federal Credit Union (“we” “us” “our”) California Privacy Policy applies to information collected from California residents who do not have personal financial accounts with us. This privacy policy does not apply to information collected from California residents who do have accounts with us for personal, family, or household purposes. Our privacy practices in connection with the information that we collect as part of a personal financial account is discussed in a separate Privacy Notice here.
We adopt this California Privacy Policy to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.
This California Privacy Policy does not address personal information collected for workforce-related inquiries or transactions. For additional details about the use of personal information for workforce matters, please refer to the Workforce Privacy Policy.
Where noted in this California Privacy Policy, the CCPA temporarily exempts some personal information reflecting a written or verbal business-to-business communication from some of its requirements. This is personal information that reflects a written or verbal communication or a transaction between the business and the consumer, where the consumer is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency and is providing the information in connection with receiving a product or service or performing a service (“B2B personal information”).
Information We Collect
Thrivent Federal Credit Union collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or device ("personal information"). In particular, Thrivent Federal Credit Union has collected the following categories of personal information from its consumers within the last twelve (12) months:
- Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number or other similar identifiers.
- Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 798.80(e)), such as name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, employment, employment history, bank account number or any other financial information, (Some personal information included in this category may overlap with other categories.)
- Protected classification characteristics under California or federal law, such as age, citizenship, religion or creed and marital status.
- Biometric information, such as fingerprints.
- Internet or other similar network activity, such as browsing history, search history, or information on a consumer's interaction with a website, application, or advertisement.
- Geolocation data, such as IP addresses, which are registered to a geographic location.
- Audio, electronic, or visual information, such as videos, photos, or voice recordings.
- Professional or employment-related information, such as current or past job history.
- Other categories of personal information, such as is described in the Thrivent Federal Credit Union Internet Privacy Policy.
- Inferences drawn from your personal information, as identified above, to create a profile about you reflecting your preferences, trends, or behaviors.
Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA's scope, including:
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Thrivent Federal Credit Union obtains the categories of personal information listed above from the following categories of sources:
- Directly from you or your agents. For example, from documents you complete, information you tell us or products and services you purchase from us.
- Indirectly from you. For example, from website usage details collected automatically on our website.
- From third parties. For example, from individuals who provide information about you in connection with our provision of products or services such as title companies, appraisers and flood certification providers.
Use of Personal Information
We may use the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry. As another example, if you provide your personal information to purchase a product or service, we will use that information to open an account and provide service throughout your relationship with us.
- To provide, support, personalize, and develop our website and services.
- To create, maintain, customize, and secure accounts with us.
- To process your requests, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To help maintain the safety, security, and integrity of our website, services, databases and other technology assets, and our business.
- For testing, research, and analysis, including to develop and improve our website and services.
- 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 or as otherwise set forth in the CCPA.
- To learn about opportunities to market other services that may be of interest to you and to market those services to you.
- To conduct internal research, such as to measure consumer interaction with Thrivent Federal Credit Union online.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Thrivent Federal Credit Union's assets, whether as a going concern or as part of receivership, liquidation, or similar proceeding, in which personal information held by Thrivent Federal Credit Union about our members is among the assets transferred.
Thrivent Federal Credit Union will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
Thrivent Federal Credit Union may disclose the information we collect about you, as listed above, with other parties. In addition to the specific situations discussed elsewhere in this policy, we share personal information with the following categories of other parties:
- Service providers:We may share information we collect with service providers who perform services on our behalf for business purposes, including marketing. When we disclose personal information to service providers, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
- Government agencies and regulators:We may share information we collect with government agencies and regulators for business purposes to demonstrate our compliance with, or as required by, various laws and regulations.
- Third parties:With your consent, we may share all categories of information that we collect.
Thrivent Federal Credit Union does not sell the personal information of consumers.
In the preceding twelve (12) months, Thrivent Federal Credit Union may have disclosed the following categories of personal information to the following categories of third parties for business purposes:
| Categories of Personal Information We Collect | To Whom We Disclose Personal Information for a Business Purpose |
|---|---|
| Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers. |
|
| Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, insurance policy number, bank account number, and other financial information. |
|
| Characteristics of protected classifications – this may include age, citizenship, religion or creed and marital status. |
|
| Biometric information – This may include fingerprints. |
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| Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement. |
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| Geolocation data – such as IP addresses, which are registered to a geographical location. |
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| Audio, electronic, visual or similar information – such as video, photos, or voice recordings. |
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| Professional or employment-related information – such as current or past job history. |
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| Inferences drawn from any of the information listed above – used to create a profile about you reflecting your preferences, trends or behaviors. |
|
How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. If we are required by law to inform you of any unauthorized access to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our services permit you to create an account. You are responsible for creating a unique and complex password and maintaining the confidentiality of any passwords that you create, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
Minors Under 16
Your children’s safety is important to us. Thrivent Federal Credit Union does not open accounts for minors without the consent of a parent or guardian and does not sell the personal information of minors under the age of 16 years of age.
Your Rights and Choices
The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise them.
Access to Specific Information and Data Portability Rights
You have the right to request that Thrivent Federal Credit Union disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- 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 that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.
We do not provide these access and data portability rights for B2B personal information.
Deletion Request Rights
You have the right to request that Thrivent Federal Credit Union delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug to identify and repair errors that impair existing intended functionality of our products and services.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We do not provide these deletion rights for B2B personal information.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 866-226-5225; or
- Submitting this online form.
Only you, or someone legally authorized to act on your behalf (an "Authorized Agent"), may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. We may request written permission from you before honoring any requests made by an Authorized Agent. Any identity verification, noted below, may still need to be completed by the consumer directly.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- If we need additional information to verify your identity prior to releasing information in accordance with your request, we may contact you at the phone number you provided in your request submission. At that time, we will conduct additional knowledge-based authentication to ensure that only those people who have a legal right to obtain information can do so.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (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 by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to provide the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.
Changes to This California Privacy Policy
Thrivent Federal Credit Union reserves the right to amend this California Privacy Policy at our discretion and at any time. When we make changes to this California Privacy Policy, we will post the updated California Privacy Policy on our website and update the policy’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Accessibility
If you are visually impaired, you may access this notice through your browser’s audio reader.
Contact Information
If you have any questions or comments about this California Privacy Policy, the ways in which Thrivent Federal Credit Union collects and uses your information described here and in our Internet Privacy Policy or Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Email: cu@thrivent.com
Postal Address:
Thrivent Federal Credit Union
Attn: Compliance Department
P.O. Box 8920
Appleton, WI 54912