Privacy Statement
At CUsource,
LLC ("CUsource, LLC", "we" or "us"), we know how important privacy is to you.
Because of our interest in protecting your privacy and that of your members,
CUsource, LLC has adopted the following general privacy principles. These
general privacy principals apply to CUsource, LLC and all subsidiaries except
where varied to accommodate a specific business unit, product or service, as
specified below.
OUR
COMMITMENT TO PRIVACY
There are
two types of information that may come into our possession: i) Information
specific to you as a financial institution; and, ii) Nonpublic Personal
Information (as that term is defined in the federal Gramm Leach Bliley Act)
about your members. We understand the importance of maintaining and protecting
information that we maintain about you or that we receive from you. We also
understand the regulatory requirements imposed on you with respect to the
sharing of Nonpublic Personal Information, and we will respect and adhere to
the re-disclosure and reuse rules set forth in the Interagency Privacy
Regulations.
Information
We Gather and What We Do With This Information
In order
to deliver the quality of service you expect from us, we may gather
entity-specific (contact, financial and other general entity information), as
well as information relating to your business needs and preferences and
non-identifiable information (such as your core system or third party vendor,
domain server, computer operating system or web browser). We collect this
information when you become a customer using methods described below and by
other publicly available means.
We
collect, retain, and use this information to: (1) protect and administer your
records and accounts; (2) comply with certain laws and regulations; (3) help us
design or improve our products and services; (4) maintain your accounts, or
otherwise meet your needs; and (5) understand your financial needs so that we
can provide you with quality products and superior service. We may also access
your information when considering a request from you for additional services or
when exercising our rights under the law or any agreement with you. We do not
share your information with third parties except as specifically described
below.
We do not
provide this information to third parties for the purpose of independent
telemarketing or direct mail marketing of any non-financial products or services
of those companies. Further, we do not reveal specific information about your
accounts or other data about you to parties outside the combined operations and
affiliates of CUsource, LLC unless: (1) you request or authorize it; (2) the
information is provided to help complete a transaction initiated by you; or (3)
the disclosure is otherwise lawfully required.
We do not
intentionally collect or retain Nonpublic Personal Information about your
members, except as specifically provided below. However, in providing services
to you we may come into possession of, or gain access to, Nonpublic Personal
Information about your members. Such services include providing software
maintenance, support, implementation, training, customization or other services
with regard to the software or services we provide, or to otherwise meet needs
that you specifically express to us. When we obtain Nonpublic Personal
Information for any of these purposes, we utilize it to accomplish the task for
which we received the information. Once the task is completed, or it is no
longer necessary for us to maintain the Nonpublic Personal Information, such
information will either be returned to you or destroyed.
Direct
Marketing
As a
customer of ours, we may contact you occasionally to introduce you to new
products and services that may be of interest, or to point out different ways
you may be able to take advantage of your current products. You can choose not
to receive marketing offers from us by direct mail, telephone and/or e-mail by
simply mailing your request to:
CUsource,
LLC
Since some
marketing programs may already be in progress, it may take six to eight weeks
to process your request. However, because of the nature of our operations,
CUsource, LLC customers who elect not to receive marketing information by
direct mail, telephone or e-mail may still be contacted:
*
As
necessary to service your account
*
To
notify you of software upgrade or release availability, or of other information
related to your licensed products, if applicable.
Agents
and Independent Contractors
To
perform certain software upgrades or changes, or to provide you with certain
services, it may be necessary to allow agents or independent contractors of
CUsource, LLC access to information about you or your members. If so, the
agents or independent contractors will be under the same restrictions as our
employees and will be bound to treat your information consistent with our
commitment to privacy and data security.
Sometimes
it is necessary to provide information about you to an "alliance
provider" or "strategic business provider" outside of CUsource,
LLC and its affiliates, so that they may provide support or services for one or
more of the products we offer. A privacy statement is on file at CUsource, LLC from all Alliance Providers.
When we
must disclose Nonpublic Personal Information to an "alliance provider" or
"strategic business provider" in order to provide a service for which you have
contracted, your agreement with us will detail this arrangement.
EXTRANET
NETWORKS
CUsource,
LLC utilizes the following extranet networks. An extranet is a private secure
network that controls and limits access to authorized users through an
established set of strict internal access authorizations, rights and
privileges. In addition, special hardware and software are used to build a
"firewall" to protect data from a public network like the Internet.
CUsource, LLC utilizes encryption technology for secure communications between
your computer and our extranet networks. We have also installed a "digital
certificate" that uses a protected method of communicating with your
browser called Secure Sockets Layer Protocol, or SSL. This means that we are
establishing a unique, private connection between your computer and our
extranet to recognize and verify your identity and that the information we send
you is really from an authorized user of one of our extranet networks. Some extranet networks we maintain are:
PC Banking - CUsource, LLC customers have access to a secure
extranet network containing various financial customer information. In order to
gain access to the site, you and your members must enter a valid login ID and
password. If you need assistance accessing the site, any information required by our customer service department
in order to facilitate your access will be used solely for this purpose. We
collect information about you or your members on this site as necessary, solely
to maintain your system or otherwise support your needs. Information collected
through this site is not shared with third parties, except as allowed by this
Privacy Statement.
cusource.com - CUsource, LLC customers have
access to a extranet network containing various customer services, and product
and industry information. Certain links on this site require a valid login ID
and password which will utilize SSL for a secure encrypted connection for
accessing sensitive information. If you need assistance accessing the site, any
information required by our customer service department in order to facilitate
your access will be used solely for this purpose. We may collect information
about you on this site as necessary to maintain our system or otherwise support
your needs. Information collected through this site is not shared with third
parties, except as allowed by this Privacy Statement.
Links to
third parties: We
may allow you to link to various third party sites. CUsource, LLC does not
control or access information you provide to third parties. CUsource, LLC is
not responsible for the privacy practices of unaffiliated third party sites to
which this Web site may link, and we encourage you to become familiar with the
privacy practices of such sites before you provide them with personal
information.
Personal
Information Related to Children: CUsource, LLC does not intend to collect personal
information from children who identify themselves as being less than 13 years
of age. Such children should not provide personal information on any CUsource,
LLC website, and should ask their parents to submit a request on their behalf
if they want to receive information related to this site.
POLICIES
APPLICABLE TO SPECIFIC PRODUCTS OR SERVICES
Because
we offer such a variety of goods and services to financial institutions, there
are certain situations in which our treatment of information you provide to us
(about you or your members and including Nonpublic Personal Information) will
differ from the above. In short, some products or services require us to
maintain and/or disclose information about you or your members. When such
treatment is required, our agreement with you will specifically address any
information sharing practices. The goods and services to which this may apply
are detailed as follows:
Core
Systems:
CUsource,
LLC offers core financial institution systems. These systems generally manage
aspects of the day-to-day operation of your institution, including management
of your member accounts and account information. They are detailed as follows.
Ultradata System
- The Ultradata
System is a data processing system designed specifically for credit unions,
which may include core processing, front office and back office solutions,
Ultra-Access Internet Banking, card services, business intelligence
applications and/or document management functionality.
We do not intentionally collect or retain Nonpublic Personal Information about
your members in order to maintain your Ultradata System. However, we may come
into contact with your Nonpublic Personal Information through the provision of
software maintenance, support, implementation, training or customization, other
services with regard to the software or services we provide, or to otherwise
meet needs that you specifically express to us. Where we obtain Nonpublic
Personal Information, it is utilized to accomplish the purpose for which you
disclosed it.
Mortgage
Solutions Products and Services - We offer mortgage origination, secondary marketing,
post-closing document tracking and other products and services through our
Mortgage Solutions Group. In trouble-shooting issues or to otherwise support or
maintain your licensed software, we will request database files containing your
member information. We utilize this information solely to process your mortgage
requests and may retain it for future use to this end unless you specifically
request otherwise. We do not use this information for any other purpose.
OUR
COMMITMENT TO DATA SECURITY
We
realize that a meaningful commitment to privacy requires that policies and
procedures be in place to assure data security. We also realize that just like
you will make an assessment of our privacy policies, you may be required to
undertake a risk assessment of our security practices. We pride ourselves on
understanding the need to safeguard sensitive information that you have
entrusted to us. CUsource, LLC values your trust and will handle your
information with care.
We
safeguard information according to established security standards and
procedures, and we continually assess new technology designed to protect the
integrity of information. Where information includes Nonpublic Personal
Information of your members these standards include internal administrative,
technical and physical safeguards designed to:
*
Ensure
the security and confidentiality of Nonpublic Personal Information shared with
us.
*
Protect
against any anticipated threats or hazards to the security or integrity of such
information.
*
Protect
against unauthorized access to or use of such information that could result in
substantial harm or inconvenience to any individual.
We have
procedures that limit access to Nonpublic Personal Information to only those
employees with a business reason to know such information about you, and our
employees are trained to understand our information sharing principles and
comply with these procedures. We educate our employees about the importance of
confidentiality and customer privacy through standard operating procedures,
special training programs and our policies. We take reasonable disciplinary
measures to enforce employee privacy responsibilities.
HOW
YOU CAN HELP
CUsource,
LLC understands that consumer privacy is important to you. You can assist in
protecting your information by recognizing the following principles.
*
If
at all possible, avoid sending unscrambled personal information about your
members. Nonpublic Personal Information about your members is often not
necessary to provide support and maintenance for our products. Test files can
alleviate the need to send us Nonpublic Personal Information. If such
information is necessary, we will specify what we need and may suggest methods
to transmit the data. However, you must determine the transmission method that
best suits your needs.
*
Realize
that, although CUsource, LLC utilizes industry-leading security technology when
receiving information via the Internet, absolute security cannot be assured.
The risk, however small, of compromising data security by transmitting via the Internet
should be weighed against the benefit of this transmission method.
We reserve the right to change these privacy and security principles, along with related provisions and policies, at any time. Notwithstanding our information sharing practices described in the above statement, information about you or your members may be disclosed to regulators, as required by law, or as allowed by our agreement with you.