Online Privacy & Security Policy (Revised 03/2019)

This Online Privacy & Security Policy (“Policy”) applies to this online interface and every online interface and mobile application offered by The Citysecurefund (US) Limited (“the Bank”) and every affiliate or subsidiary online interface that links to this Policy. The terms “Bank” or “we” or “us” or “our” in this Policy refers to the Bank and its affiliates and subsidiaries; and the terms ‘you’, ‘your’ and ‘yours’ means you, the person(s) accessing this Site and any party on whose behalf you are doing so.

This Policy also covers the Bank’s many online services, including our websites, Online Banking, SMS Banking, the Mobile Banking Application and our branded social media sites or pages, as well as any interactions you may have while viewing content provided through one of our digital advertising campaigns (collectively, “online services”). This Policy (together with the Bank’s Client Deposit and Services Agreement, the Specific Terms and Conditions concerning Online Banking Access and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, via our online services will be processed by us.

This Policy explains how we may collect information from you online when you visit or use these online services offered by the Bank, its affiliates and subsidiaries that link to or reference this Policy.

Protecting Information about You from Marketers Outside United National Federal Credit Union

Customer Information means personally identifiable information about you, such as information you provide via forms, surveys, applications or other online fields including your name, postal or email addresses, telephone, fax or mobile numbers or account numbers. Unlike many other financial institutions, the Bank does not sell or share any customer information with marketers outside the Bank who may want to offer you their own products and services. However, customer information may be disclosed or transferred to agents or third parties authorised to act on our behalf for the purposes of providing the designated services of the Bank or to regulators or supervisory authorities as required by law.

Making Security of Information a Priority

Keeping financial information secure is one of our most important responsibilities. We maintain physical, electronic and procedural safeguards to protect customer information. Our employees are bound by a Code of Conduct that requires confidential treatment of customer information and are subject to disciplinary action if they fail to follow this code.

Collection of Information

When you visit or use our online services, we may collect personal information from or about you, such as your name, email address, mailing address, telephone numbers, account numbers, username, and password. We may also collect payment card information, social security numbers, and driver’s license numbers.

We may collect certain information about your use of our online services. For example, we may capture the IP address of the device you use to connect to the online service, the type of operating system and browser you use, and information about the site you came from, the parts of our online service you access.

We may also use cookies, web beacons or other technologies to collect and store other information about your visit to, or use of, our online services. Cookies, by themselves, cannot be used to find out the identity of any user.

We may also collect information through your browser and/or device. We may use this information to ensure that our websites are functioning properly, for fraud detection and prevention and security purposes.

For your convenience, the Bank offers you the ability to access some of our products and services through our Mobile Banking Application (the “App”). When you interact with us through this App, we may collect data as needed, but that data will never be shared outside the Bank; such as unique device identifiers for your mobile device, your screen resolution and other device settings, information about your location, and analytical information about how you use your mobile device. We may ask your permission before collecting certain information (such as precise geolocation information) through the App.

We may also collect information about your online transactions and account experience, as well as information about our online communications with you. Examples include your payment histories, account balances and other transaction records.

How we may share information

The Bank does not sell or share customer information collected from our online services with marketers outside the Bank, who may want to offer you their own products and services. We grant access to personal information about you (such as your name, address, and social security number and credit history) to company employees so that they can provide or offer products and services to you, process and service your accounts, and administer our business.

We may share customer information within our correspondent banks and our affiliates who are contractually obligated to keep the information we provide to them confidential and to use the customer information we share only to provide the services we ask them to perform for you and us. We also may share Customer Information we collect about you online to anyone who the Bank reasonably believes is conducting a legitimate credit inquiry, including without limitation, inquires to verify existence or condition of an account for a third party such as a lender, merchant or credit bureau, in response to any subpoena, summons, court or administrative order, or other legal process issued by a regulatory, administrative or judicial authority or tribunal whether within or outside US, which the Bank believes requires its compliance; on a closed account, if the Bank reasonably believe you have mishandled it; in connection with collection of indebtedness or to report losses incurred by the Bank; in compliance with any agreement between the Bank and a professional, regulatory or disciplinary body or with the laws of US; in connection with potential sales of businesses and to carefully selected service providers or third parties who help the Bank meet customer’s needs by providing or offering Bank services or their own products or services; in connection with the sale of our Bank or banking business of the Bank to a third party.

Our Code of Conduct requires that your information remain confidential, subject to the terms and conditions of any agreements you have made with us. Even if you are no longer our customer, we will continue to treat your nonpublic personal information in the same way as if you were still a customer. In addition, we maintain physical, electronic and procedural safeguards to guard this personal information.

How We Use Your Information

We may use all the information that we collect, as described above, for the following purposes:

To provide you with the products and services you requested.

Preventing fraud and enhancing the security of your account or our online services.

To comply with banking, regulatory reporting and other legal requirements.

Operating, evaluating and improving our business, including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing, and other internal functions.

To deliver marketing communications that we believe may be of interest to you, including ads or offers which have been tailored to suit you.

To verify your identity and/or location (or that of your authorised agents) in order to allow access to your accounts, conduct online transactions.

To comply with legal processes and law enforcement requirements.

Linking to Other Sites

We may provide links to non-Bank companies, such as credit bureaus or merchants. If you choose to link to websites not controlled by the Bank, we are not responsible for the privacy or security of these sites, including the accuracy, completeness, reliability or suitability of their information. If you are asked to provide information on one of these websites, we strongly urge you to carefully study their privacy policies before sharing your information.

Changes to the Privacy & Security Policy

If we make changes to our Privacy & Security Policy or make any material changes to our online services, we will revise this Policy to reflect such changes and revise the Policy effective date. It is your responsibility to review this Privacy & Security Policy frequently and remain informed about any changes to it, so we encourage you to visit this page often. Any changes to the Policy will become effective when the revised Policy is posted on our website. Your continued use of our online services constitutes your acceptance of such changes and the most recent versions of this Policy.