California Privacy Notice

This California Privacy Notice ("California Notice") supplements the Online Privacy Policy and the Consumer Privacy Notice, and applies to you only if you are a resident of the State of California. The terms "Bethpage," "we," "our," and "us" in this California Privacy Notice refer to Bethpage Federal Credit Union and/or its affiliates or subsidiaries, and we have adopted this California Notice to comply with California privacy laws, including the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"). This California Notice applies to visitors, users, members, employees, job applicants, independent contractors and others who are California residents (collectively, "consumers" or "you").

This California Notice applies to California residents' Personal Information, as defined below, we collect to provide them with certain financial products and services (collectively, "Services"). The California Notice does not apply to Personal Information for some of our Services that are excepted from the CCPA and CPRA, such as those subject to the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley (GLBA) or the California Financial Information Privacy Act (CalFIPA).

Table of Contents
I. NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION
II. YOUR CALIFORNIA PRIVACY RIGHTS
III. SUBMITTING A VERIFIED CONSUMER REQUEST
IV. SALE OR SHARING OF PERSONAL INFORMATION
V. MODIFICATIONS AND UPDATES TO THIS CALIFORNIA NOTICE
VI. ADDITIONAL INFORMATION AND ASSISTANCE

I. NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION

We collect certain information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you ("Personal Information"), as further described below. In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not Personal Information. To the extent this data is stored or associated with Personal Information, it will be treated as Personal Information; otherwise, the data is not subject to this notice.

Categories of Personal Information:

In the last twelve (12) months, we have collected the following categories of Personal Information:

Personal Identifiers, including those listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)), such as a real name, account name, signature, social security number, physical characteristics or description, mailing 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, and other financial information, email address, online identifier, internet protocol (IP) address, device type, mobile device identifier, and other similar identifiers.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, such as the pages visited; the sites used before or after visiting ours; your actions within the Services; the type of content or advertisements accessed, seen, forwarded and/or clicked on; Wi-Fi connections; date and time stamps; log files; and diagnostic, crash, website, and performance logs and reports.
Geolocation data.
Professional or employment information, such as title, salary, employment records, and references.
Education information, such as details of your education history and qualifications.
Audio, electronic, and similar information, such as calls and messages on our customer service phone line.
Biometric information, including, physiological, biological and behavioral characteristics, such as face imagery and keystroke patterns.
Inferences drawn from any of the information above to create a profile about an individual reflecting the individual's preferences, characteristics, and transaction behavior.
Personal Information that is defined as "Sensitive Personal Information," such as Personal Information that reveals a consumer's:
- Social security, driver's license, state identification card, or passport number of our (i) consumers to obtain our Services and for account opening purposes; and (ii) employees and job applicants as a part of the recruitment and onboarding process.
- Account log-in, financial account, debit card, or credit card in combination with any required security or access code, password, or credentials allowing access to an account of our members and employees for fraud detection and prevention and security.
- Precise geolocation to provide you with personalized content or ads for marketing purposes.
- Racial or ethnic origin of our (i) members to comply with federal Regulation C; and (ii) employees if they volunteer this information for Bethpage's DEI initiatives and participation in affinity groups.
- The contents of an employee's business email and text messages on Bethpage owned devices unless the business is the intended recipient of the communication.

We will not collect additional categories of Personal Information other than those categories listed above. If we intend to collect additional categories of Personal Information, we will provide you with a new notice at or before the time of collection.

Retention of Personal Information

We retain your Personal Information pursuant to our Records Retention Schedule. The length of time that we intend to retain each category of Personal Information will depend on a number of criteria, including (i) the length of time we are required to retain Personal Information in order to comply with applicable legal and regulatory requirements, (ii) the length of time we may need to retain Personal Information in order to accomplish the business or commercial purpose(s) for which such Personal Information is collected, used or disclosed (as indicated in this California Notice), and (iii) whether you choose to exercise your right, subject to certain exceptions, to request deletion of your Personal Information.

Use of Personal Information:

We collect and process your Personal Information for the following business and commercial purposes:

To personalize your experience on the Site.
To allow you to apply for products or services and to evaluate your eligibility for such products or services.
To respond to your inquiries and fulfill your requests.
To inform you about important information regarding the Site, products, or services for which you have enrolled in, applied for, or may be interested in applying for, as well as changes to terms, conditions, and policies, and/or other administrative information.
To deliver marketing communications that may be of interest to you, including advertisements or offers tailored to you.
To verify your identity and/or location in order to allow access to your accounts, conduct online transactions, and to prevent fraud and protect the security of your information and the Site.
To allow you to participate in surveys and other forms of market research, sweepstakes, contests, and similar promotions and to administer these activities.
To comply with laws and regulations, and to comply with other legal process and law enforcement requirements.
To recognize your device and to allow you to use online products and services.
To remember your personal settings including preferences and otherwise personalize your experience on the Site.
To facilitate navigation of the Site and ensure technological compatibility with your device.
To display information more effectively and understand how account holders and visitors use the Site.
To improve our products and services.
To provide advertisements and marketing offers and measure the effectiveness of our advertisements and content.
To ensure the Site functions properly.
For fraud detection and prevention and security purposes.
To collect statistical information and conduct aggregate analyses on usage patterns of the Site and response rates.
To help diagnose server problems.
To help determine which advertisements and offers to present and to make those advertisements and offers more relevant or of interest you.
Recruitment of employees and processing and managing job applicants.
Conducting pre-employment screening and background checks of job applicants.
Compensation and expense management for employees and independent contractors.
Benefits administration for employees and independent contractors.
General human resources management for employees and independent contractors.
Training and professional development to employees.

We will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with notice.

Sources of Personal Information

We collect Personal Information from the following categories of sources:

Information You Choose to Submit. We receive and store any information you enter on the Site or when you contact us or otherwise communicate with us, such as information provided through forms, surveys, applications, other online fields, when you choose to use the QR Code feature on our mobile app to make payments through Zelle, we may collect or access pictures and other information stored on your device's contacts, camera, and photos, or given to us in any other way. You can enable or disable access to the information we collect from your mobile device any time, through your device settings.
Information from Service Providers and Public Sources. We may obtain information that is publicly available, and we contract with certain other parties to provide certain services to allow us to provide our services and operate our business.
Information from your Browser or Device. Most browsers and devices collect and share certain information, such as Internet Protocol (IP) address, device type, screen resolution, operating system version, internet browser type and version, and geo-location of the device.
Information Collected Through Cookies - Like many websites, we use cookies to enhance your experience on the Site. Cookies are small text files that are placed on your computer or device to distinguish you from other visitors to the Site. We and/or our third-party advertising providers may place cookies or similar files on your hard drive to collect or track information about your activities while using the Site, including time spent on the Site, pages visited, and your relationship with us. For more information on cookie usage, see our Online Privacy Policy.
From our Data Analytics Providers. For example, we and our technology providers automatically collect data related to your use of the Services through the use of logging and analytics tools (such as Google Analytics), cookies, web beacons (transparent graphical images placed on a website), pixel tags, Flash objects and other tracking technologies and as a result of your use of and access to the Site, such as the pages you visit, the sites you use before or after visiting ours, your actions within the Site, the type of content or advertisements you have accessed, seen, forwarded and/or clicked on, Wi-Fi connections, date and time stamps, log files, and diagnostic, crash, website, and performance logs and reports.
Advertising Providers. Our third-party advertising services (such as Facebook and DoubleClick) use cookies, web beacons, pixel tags, Flash objects and other tracking technologies to collect information about your online activity and provide online behavioral advertising.
Biometrics and Fraud Prevention Providers. We collect biometric information for identification, security and fraud protection purposes through our third-party service providers, BioCatch (which collects keystroke patterns) and Socure (which collects face imagery). If you choose to use the QR Code feature on our mobile app to make payments through Zelle, we may collect or access pictures and other information from your device's camera, and photos. You can enable or disable access to the information we collect from your mobile device any time, through your device settings.
Information from other Sources. For employees, job applicants and independent contractors, we may combine Personal Information you voluntarily provide to us with information we collect from other sources (such as recruiters, prior employers and professional references, pre-employment screening, drug testing and background check services, and credentialing and licensing organizations).

II. YOUR CALIFORNIA PRIVACY RIGHTS

The CCPA and CPRA provide California residents with the following rights with respect to certain Personal Information:

Right to Know: You have the right to request that we disclose certain information to you about the Personal Information we collected, used, disclosed, sold and shared about you in the past twelve (12) months. This includes a request to know any or all of the following:
- The categories of Personal Information collected about you;
- The categories of sources from which we collected your Personal Information;
- The categories of Personal Information that we have sold or disclosed about you for a business purpose;
- The categories of third parties to whom your Personal Information was shared, sold or disclosed for a business purpose;
- Our business or commercial purpose for collecting or selling your Personal Information;
- The specific pieces of Personal Information we have collected about you; and
- The retention period or criteria used for retention.
Data Portability: You have the right to request a copy of Personal Information we have collected and maintained about you in the past twelve (12) months.
Right to Correct: In certain circumstances, you have the right to correction of your inaccurate Personal Information. If you are a member, you may access your online account through the websites and mobile app and update your Personal Information. In addition, consumers may also contact us as outlined in "Section III. SUBMITTING A VERIFIED CONSUMER REQUEST" to request the change. We will use commercially reasonable efforts to honor your requests.
Right to Deletion: You have the right to request that we delete Personal Information we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your Personal Information, we may deny your request or may retain certain elements of your Personal Information as permitted by law, including:
- Personal Information that is not subject to the CCPA or the CPRA.
- To complete the transaction for which the Personal Information was collected, provide a product or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.
- To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- To debug to identify and repair errors that impair existing intended functionality.
- To exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- To comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- To 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 deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
- To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
- To comply with a legal obligation.
- To otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Opt-Out/In: You have the right to opt-out of the "Sale" or "Sharing" of your Personal Information as defined by the CCPA and the CPRA. You also have the right to opt-in to the Sale of Personal Information. Please see our Notice of Right to Opt-Out on our Do Not Sell or Share My Personal Information page for more information about your opt-out/in rights. In addition, if you do not want to receive interest-based advertisements, you can limit the collection of certain information through your device's settings. To limit collection of information from mobile devices, including location data, please visit your device's settings to set the "Limit Ad Track", "Location Based Services," or other similar feature on your device. You can also make choices about data collection for certain companies by visiting an industry consumer choice platform such as the NAI (https://optout.networkadvertising.org/) or DAA (https://optout.aboutads.info/). You may still receive ads after limiting processing of information for interest-based advertising, but those ads may be less relevant to your interests.
Right to Limit the Use of Sensitive Personal Information: We limit our use of Sensitive Personal Information to only the purposes necessary to perform covered Services, and for certain business and commercial purposes described above.
Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of your CCPA or CPRA privacy rights.

Some of our products and services, however, may require your Personal Information. If you choose not to provide your Personal Information that is necessary to provide any aspect of our products or services, you may not be able to use those products or services.

III. SUBMITTING A VERIFIED CONSUMER REQUEST

To exercise your rights, you must provide us with sufficient information to allow us to verify your identity, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Once we receive the information you provide to us, we will review it and determine if more information is necessary to verify your identity as required by law, and we may request additional information in order to do so.

To exercise your California privacy rights described above, please submit a verifiable request to us by:

Visiting: https://www.bethpagefcu.com/ccpa-request-form.
Calling us at 1-800-628-7070.

Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for Right to Know or Data Portability twice within a twelve (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. We will need to verify your identity with at least two (2) pieces of information, such as name and email address.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. We will only use Personal Information provided in a verifiable consumer request to verify the request's identity or authority to make the request.

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

We will acknowledge receipt of the request within ten (10) business days of its receipt. We will 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. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. 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 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.

Consumer Request by an Authorized Agent

If any authorized agent submits a consumer request on your behalf, in order to confirm that person or entity's authority to act on your behalf and verify the authorized agent's identity, we require the below items:

To verify your authorization to request on behalf of a California resident, provide one or more of the following: (1) California Secretary of State authorization, (2) written permission from the California resident, or (3) power of attorney.
Sufficient information to verify the authorized agent's identity, depending on the nature of the request.
To verify the identity of the California resident for whom the request is being made, provide the information set forth above for verification of the consumer request.

IV. SALE OR SHARING OF PERSONAL INFORMATION

We do not sell your Personal Information, subject to the CCPA or CPRA to third parties for money. However, the CCPA and the CPRA defines "Sale" broadly, and that definition could include information that we have shared with certain technology providers that provide certain services to us, including delivering advertisements that we believe may be of interest to you. In the past twelve (12) months, we have "sold" (as defined under the CCPA and CPRA) the following categories of Personal Information to the following categories of third parties: (See Categories of Personal Information):

Category 1 (e.g. Identifiers): Advertising Providers.
Category 2 (e.g. Commercial Information): Advertising Providers.
Category 3 (e.g. Online Activities): Advertising Providers.
Category 4 (e.g. Geolocation Data): Advertising Providers.

We "Sell" (as defined under the CCPA or CPRA) your Personal Information for the following business or commercial purposes:

Marketing our products and services to you, including sending you promotional or marketing communications, which may include contests, promotions, and special offers for products and services.
Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions.

We may "Share" your Personal Information for the purposes of "cross-context behavioral advertising" as defined by the CPRA. Cross-context behavioral advertising is "the targeting of advertising to a consumer based on the consumer's personal information obtained from the consumer's activity across businesses, distinctly-branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the consumer intentionally interacts."

Within the last twelve (12) months, we have "Shared" the following categories of Personal Information necessary to provide you with personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as reporting, analytics, and market research. We have "Shared" your Personal Information with the following categories of third parties (See Categories of Personal Information):

Category 1 (e.g. Identifiers): Advertising Providers (as described above).
Category 2 (e.g. Commercial Information): Advertising Providers.
Category 3 (e.g. Online Activities): Advertising Providers.
Category 4 (e.g. Geolocation Data): Advertising Providers.

In addition, we share Personal Information that is not subject to CCPA or CPRA as provided in our Consumer Privacy Notice, which also includes information on how to opt out of or limit the sharing of certain information.

Finally, we may share your Personal Information: (i) in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law; (ii) when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Consumer Member Account Agreement and our Business Member Account Agreement and other agreements; or (iii) in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

We do not and will not knowingly Sell or Share Personal Information of minors under the age of 16.

Do Not Track

We use analytics systems and providers and participate in advertising networks that process Personal Information about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We are not currently able to, and do not, process or comply with any web browser's "do not track" signal or similar mechanisms.

Note, however, that you may find information about how to opt out of or block certain technologies as described under Automatically Collected Information in our Online Privacy Policy.

V. MODIFICATIONS AND UPDATES TO THIS CALIFORNIA NOTICE

This California Notice is subject to change. It is your responsibility to review this California Notice and remain informed about any changes to it. Any changes to this California Notice will become effective when we post the revised California Notice on the Site. Your use of the Site following these changes constitutes acceptance of any amendments to and the most recent of this California Notice.

VI. ADDITIONAL INFORMATION AND ASSISTANCE

If you have any questions or concerns about this California Notice and/or how we process Personal Information, please contact us at: privacy@bethpagefcu.com.

Last Updated: April 1, 2024