Privacy & security

California privacy policy last updated June 30, 2023.

This Thrivent Federal Credit Union (“Thrivent Federal Credit Union,” “we,” “us,” or “our”) California Privacy Policy (“Policy”) applies to information collected from California residents who do not have personal financial accounts with us.

We adopt this Policy to comply with the California Consumer Privacy Act of 2018 (CCPA) as modified by the California Privacy Rights Act (CPRA) and implementing regulations, collectively referred to as CCPA and any terms defined in the CCPA have the same meaning when used in this Policy.

Applicability

This Policy describes how we collect, use, share, disclose, retain, and secure the personal information covered under the CCPA, including through our website, https://www.thriventcu.com/ (the “Site”), when you interact with us as a customer, or otherwise.

Under the CCPA, personal information means information that identifies, relates to, or could be reasonably linked directly or indirectly to a particular California resident. It also includes certain categories of information that qualify as Sensitive Personal Information, identified below. Please note that the CCPA does not apply to certain categories of information, such as those subject to the Gramm-Leach-Bliley Act (“GLBA”). Therefore, this Policy does not apply to information that we collect about California residents who apply for or obtain financial products and services for personal, family, or household purposes. Such customers can learn more by viewing our Privacy Notice, available here

This 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

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:

Category¹	Examples	Collected	Retention Period
A. Identifiers	A 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.	Yes	For the duration of your relationship with us plus any legal or regulatory retention period.
B. Personal Information	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, 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.	Yes	For the duration of your relationship with us plus any legal or regulatory retention period.
C. Protected Classification Characteristics Under California 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).	Yes	For the duration of your relationship with us plus any legal or regulatory retention period.
D. Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No	N/A
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.	No	N/A
F. Internet or Other Similar Network Activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes	For the duration of your relationship with us plus any legal or regulatory retention period.
G. Geolocation Data	Physical location or movements.	Yes	For the duration of your relationship with us plus any legal or regulatory retention period.
H. Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes	For the duration of your relationship with us plus any legal or regulatory retention period.
I. Professional or Employment-Related Information	Current or past job history or performance evaluations.	Yes	For the duration of your relationship with us plus any legal or regulatory retention period.
J. Non-Public Education Information	Education 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.	No	N/A
K. Inferences Drawn of the Consumer	Inferences drawn from Personal Information identified above to create a profile about a consumer reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes	For the duration of your relationship with us plus any legal or regulatory retention period.
L. Sensitive Personal Information	Personal information that reveals (a) Social Security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credential allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; or (f) genetic data. Biometric information processed for the purpose of uniquely identifying a consumer, personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. Some Sensitive Personal Information included in this category may overlap with other categories. Purposes for collection: Processing and ongoing maintenance. Is the Sensitive Personal Information sold or shared? No	Yes	For the duration of your relationship with us plus any legal or regulatory retention period.

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 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.

¹Categories of personal information are as defined in Cal. Civ. Code. § 1798.140(v) (effective Jan. 1, 2023).

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.

Disclosure of 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 disclose personal information to the following categories of other parties:

Service providers: We may disclose 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 disclose 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 disclose all categories of information that we collect.

Categories of personal information collected and to whom it is disclosed

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:

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. This information can be shared with:

Advertising networks
Data analytics providers
Government agencies or regulators as may be needed to demonstrate our compliance with, or as required by, various laws and regulations or to prevent illegal activity.
Internet service providers
Joint marketing partners
Operating systems and platforms
Payment processors and financial institutions
Professional services organizations, this may include auditors and law firms
Social networks
Other Service Providers

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. This information can be shared with:

Government agencies or regulators as may be needed to demonstrate our compliance with, or as required by, various laws and regulations or to prevent illegal activity.
Operating systems and platforms
Payment processors and financial institutions
Professional services organizations, this may include auditors and law firms
Other Service Providers

Characteristics of protected classifications – this may include age, citizenship, religion or creed and marital status.

Government agencies or regulators as may be needed to demonstrate our compliance with, or as required by, various laws and regulations or to prevent illegal activity.
Operating systems and platforms
Professional services organizations, this may include auditors and law firms
Other Service Providers

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.

Advertising networks
Data analytics providers
Government agencies or regulators as may be needed to demonstrate our compliance with, or as required by, various laws and regulations or to prevent illegal activity.
Internet service providers
Operating systems and platforms
Professional services organizations, this may include auditors and law firms
Social networks
Other Service Providers

Geolocation data – such as IP addresses, which are registered to a geographical location.

Government agencies or regulators as may be needed to demonstrate our compliance with, or as required by, various laws and regulations or to prevent illegal activity.
Internet service providers
Operating systems and platforms
Professional services organizations, this may include auditors and law firms
Other Service Providers

Audio, electronic, visual or similar information – such as video, photos, or voice recordings.

Advertising networks
Government agencies or regulators as may be needed to demonstrate our compliance with, or as required by, various laws and regulations or to prevent illegal activity.
Internet service providers
Operating systems and platforms
Professional services organizations, this may include auditors and law firms
Other Service Providers

Professional or employment-related information – such as current or past job history.

Government agencies or regulators as may be needed to demonstrate our compliance with, or as required by, various laws and regulations or to prevent illegal activity.
Operating systems and platforms
Professional services organizations, this may include auditors and law firms
Other Service Providers

Inferences drawn from any of the information listed above – used to create a profile about you reflecting your preferences, trends or behaviors.

Advertising networks
Data analytics providers
Joint marketing partners
Operating systems and platforms
Other Service Providers

Sensitive personal information

Government agencies or regulators as may be needed to demonstrate our compliance with, or as required by, various laws and regulations or to prevent illegal activity.
Operating systems and platforms
Professional services organizations, this may include auditors and law firms
Other Service Providers

In the preceding twelve (12) months, we have shared for cross-contextual advertising (i.e., online behavioral advertising) the following categories of personal information about consumers to third-parties so they can market products, information, campaigns, or services to you:

Identifiers
Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Internet or other electronic network activity information
Geolocation data
Inferences drawn from any of the information listed above

In the preceding twelve (12) months, we have not sold the personal information of any consumer for monetary consideration. But our use of cookies and other tracking technologies may be considered a sale of personal information under the CCPA. Categories of personal information that we have sold under the CCPA include identifiers (e.g., IP addresses) and Internet or other similar network activity information. Categories of third parties to whom personal information is sold under the CCPA include data analytics providers and marketing providers.

You can make your privacy choices regarding our tracking technologies for analytics and advertising service providers by clicking the Accept button in the pop-up banner at the bottom of the screen. We also recognize the Global Privacy Control ("GPC") signals that are trasnmitted by web browsers. Your browser must be able to support GPC for us to regoznize your opt-out preference signal. For more information about GPC, please visit Global Privacy Control.

If you want to change your choices you will need to clear the cookies in your browser and the next time you visit our site you will be presented with the pop-up banner. Please note that your use of our website may still be tracked by Thrivent Federal Credit Union and its service providers.

In the preceding twelve (12) months, we have not processed sensitive personal information as defined by the CCPA pursuant to this Policy for purposes other than those specifically authorized Section 7027(m) of the CCPA regulations.

We have not knowingly collected, sold, or shared personal information of consumers under sixteen (16) years of age.

Retention of Personal Information

The length of time that we intend to retain each category of Personal Information depends on a number of criteria, including (i) the nature of our relationship with you; (ii) any legally required data retention periods; (iii) the length of time we may need to retain your information in order to accomplish the business or commercial purpose(s) for which we process such information; and (iv) whether you choose to exercise your right, subject to certain exceptions, to request deletion of your information.

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 knowingly collect 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

California residents have the right to request that Thrivent Federal Credit Union disclose certain information to you about our collection, use, and disclosure of your personal information upon receipt of a verifiable request. There are two types of Rights to Know requests that you can make:

Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
1. Categories of personal information collected, sold, or shared;
2. Categories of sources from which personal information is collected;
3. Categories of third parties to whom the information is sold, shared or disclosed;
4. Business or commercial purpose for collecting, sharing, or selling personal information;
5. Categories of personal information disclosed for a business purpose and categories of persons to whom it was disclosed for a business purpose.
Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
1. Specific pieces of personal information collected about you.

This information will be provided to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

There are certain exceptions to a consumer’s Right to Know. We will state in our response if an exception applies.

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 upon receipt of a verifiable request. This right is subject to certain exceptions. We will state in our response if an exception applies.

Right of Correction

If we maintain inaccurate personal information about you, then you have the right to request that we correct the inaccurate personal information upon receipt of a verifiable request. This right is subject to exceptions. We will state in our response if an exception applies.

Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to opt-out of the sale or sharing of your personal information by a business subject to certain laws and regulations. As described above, although we do not sell your information for monetary consideration, our use of online trackers and cookies may constitute a sale or sharing under California law. Therefore, we allow you to make your privacy choices regarding our use of these online trackers by clicking the Accept button in the pop-up banner at the bottom of the screen.

We recognize the Global Privacy Control (“GPC”) signals that are transmitted by web browsers. Your browser must be able to support GPC for us to recognize your opt-out preference signal. For more information about GPC, please visit Global Privacy Control.

Please note that opt-out choices may be stored via cookies. If you clear cookies, if your browser blocks cookies, or if you view the page from a different browser or device, your opt-out choice may no longer be logged or recognized.

Right to Limit Use and Disclosure of Sensitive Personal Information

If we process Sensitive Personal Information (as defined in Cal. Civ. Code § 1798.140(ae)), we only do so for the purposes specifically authorized by California law and in a manner that is necessary and proportionate for those purposes. As such, we do not perform any processing for which a Right to Limit request is available.

Submitting Rights Requests

To exercise the 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 and registered with the California Secretary of State (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. We reserve the right to take additional steps as necessary to verify the identity of California consumers where we have reason to believe a request is fraudulent.

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.

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. We will not:

Deny goods or services to you;
Charge you a different price, including through the use of discounts or other benefits or imposing penalties;
Provide a different level of quality of goods or services to you; or
Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

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 Last Updated 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 policy 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

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