Privacy Policy

Privacy Policy

Biometric Information Privacy Policy and Consent

Effective Date: July 25, 2023

BIOMETRIC INFORMATION PRIVACY POLICY AND CONSENT

Scope and Overview

This policy outlines how RIPCO Credit Union, its vendors, and/or the licensor of the RIPCO Credit Union’s consumer verification software processes biometric data collected from you for identity verification and fraud prevention purposes.

Biometric Data Defined

As used in this policy, biometric data includes “biometric identifiers” and “biometric information”. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. As the term is used in this policy, the selfie photograph you upload to the software for use in the biometric algorithm is considered a "biometric identifier." “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.

Disclosure and Authorization Policy

To the extent that RIPCO Credit Union, its vendors, and/or the licensor of the RIPCO Credit Union’s consumer verification software collect, capture, or otherwise obtain biometric data relating to a consumer, RIPCO Credit Union must first:

Inform each consumer that RIPCO Credit Union, its vendors, and/or the licensor of the RIPCO Credit Union’s consumer verification software are collecting, capturing, or otherwise obtaining the employee’s biometric data, and that the RIPCO Credit Union is providing such biometric data to its vendors and the licensor of the RIPCO Credit Union’s consumer verification software;

Inform the consumer of the specific purpose and length of time for which the consumer’s biometric data is being collected, stored, and used; and

Receive consent by the consumer authorizing RIPCO Credit Union, its vendors, and/or RIPCO Credit Union’s consumer verification software to collect, store, and use the consumer’s biometric data for the specific purposes disclosed by the RIPCO Credit Union, and for RIPCO Credit Union to provide such biometric data to its vendors and the licensor of the RIPCO Credit Union’s consumer verification software.

RIPCO Credit Union, its vendors, and/or the licensor of the RIPCO Credit Union’s consumer verification software will not sell, lease, trade, or otherwise profit from employees’ biometric data; provided, however, that the RIPCO Credit Union’s vendors and the licensor of the RIPCO Credit Union’s consumer verification software may be paid for products or services used by RIPCO Credit Union that utilize such biometric data.

This policy is intended to comply with all federal, state, and local laws.

Purpose for the Collection of Biometric Data

RIPCO Credit Union, its vendors, and/or the licensor of RIPCO Credit Union’s consumer verification software collect, store, and use biometric data solely for identity verification and fraud prevention purposes.

Disclosure

RIPCO Credit Union will not disclose or disseminate any biometric data to anyone other than its vendors and the licensor of the RIPCO Credit Union’s consumer verification software providing products and services using biometric data without/unless:

First obtaining consumer consent to such disclosure or dissemination;

The disclosed data completes a financial transaction requested or authorized by the consumer;

Disclosure is required by law or ordinance; or

Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Security

RIPCO Credit Union shall use a commercially reasonable standard of care to store, transmit and protect from disclosure any biometric data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which RIPCO Credit Union stores, transmits and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual or an individual’s account or property, such as genetic markers, genetic testing information, account numbers, PINs, driver’s license numbers and social security numbers.

Retention

RIPCO Credit Union shall retain consumer biometric data only until, and shall request that its vendors and the licensor of RIPCO Credit Union’s consumer verification software permanently destroy such data when, the first of the following occurs:

The initial purpose for collecting or obtaining such biometric data has been satisfied, such as verification of consumer identity;

Request of consumer to destroy the biometric data; or

Within 30 days of consumer’s provisioning of biometric data.

Contact Information

If you have any questions about our use, storage, or security of your biometric data you can contact us at: ripco@ripco.org.

Biometric Information Consumer Consent

As outlined in the “Biometric Information Privacy Policy”, I understand and consent to the collection, use, retention, storage, and/or disclosure or re-disclosure of data or images from biometric verification technology by RIPCO Credit Union, its vendors, and/or the licensor of the RIPCO Credit Union’s consumer verification software. I acknowledge that I have been given a copy of the Policy, or that the Policy has been made accessible to me, and I have had an opportunity to review it and request any additional information concerning the RIPCO Credit Union’s procedures and safeguards
for collecting, maintaining, using, disclosing, sharing, storing, and/or destroying this data.

Children’s Online Privacy Protection

Ripco Credit Union recognizes its responsibility to protect the privacy of our youngest members.  Ripco Credit Union is committed to protecting our young members and other visitors as they visit our kids section of our website.  The following language appears on the Ripco Credit Union website on the “Kids Page”:

Ripco Credit Union respects the privacy of children. Ripco does not knowingly collect, maintain or use personal information from our website about children under age 13. We do not knowingly market to children, nor do we disclose any child’s personally identifiable information to any third party for marketing purposes. If a child whom we know to be under age 13 sends personal information to us online, we will only use that information to respond directly to that child, notify parents, or seek parental consent.

It is the intent of Ripco Credit Union to comply with the Children’s Online Privacy Act (COPPA) that governs and protects the privacy of our youngest members.

If young members send us email with their personal information for any reason, we will respond to their email as appropriate and then promptly delete the child’s email address. 

We will not sell, give, or share their personal information to/with any third party vendor or any other organization.  We will not require a child to disclose more information than is reasonably necessary to participate in an activity.

We will use the “one time contact” exception under the rule if we collect children’s online contact information, and only this information, to enter them into a contest, and then only contact such children once the contest ends to notify them if they have won or lost. At that point, we will delete the online contact information we have collected.

A description of parental rights:

• Ripco Credit Union won’t require a child to disclose more information than is reasonably necessary to participate in an activity;
• Parents can review their child’s personal information, direct us to delete it, and refuse to allow any further collection or use of their child’s information;
• Parents may agree to the collection and use of their child’s information, but still not allow disclosure to third parties unless that’s part of the service (for example, social networking); and
• Parents may exercise their rights by contacting the credit union in person, via phone, email or text.  This communication will be considered duly received and the request honored upon Ripco Credit Union’s confirmation of receipt of the request via the same medium as that used by the parent(s) to initiate the request.

Online Privacy Policy

Introduction

Ripco Credit Union (RCU) (or "We", "us" and "our”) is committed to providing financial products and services that enable our members to meet their financial needs and goals while at the same time protecting the members’ nonpublic personal information. By visiting our website, and using our services, you acknowledge and agree to the collection, use, and other processing of your information in accordance with the practices described in this privacy policy. If you do not agree to all of the terms, conditions, and practices set forth herein, do not access the website or any of its pages or use our other web or mobile services.

Security

As governed by our Privacy Policy, RCU has established appropriate security standards to protect against unauthorized access to member information. We restrict access to nonpublic personal information to those employees who need to have that information in order to provide products or services.

Information We May Collect, Use, Share

RCU will only collect personal information necessary to conduct our business. That means only what is necessary to provide competitive financial products and services and no more. We collect this information about members from applications and other services, information about member transactions with us and information we receive from consumer reporting agencies. With your consent, RCU only shares information for legitimate business reasons, with the ultimate goal of bringing members greater convenience and more choices.

Cookies/Links

A cookie is a piece of data from a website that is stored within a web browser that the website can
retrieve at a later time. Cookies are used remember specific information about the user as you navigate the website or return to the website. Our cookies do not store personal or sensitive information. If you do not want a cookie placed on your computer as a result of using the website or services, you may disable cookies altogether by setting your browser or third-party software to reject cookies. Due to www.ripco.org being a secured website, when you leave our website to go to another linked site, you will be provided a disclaimer:

“You are now leaving our website to visit a third-party site. We are not
responsible or liable for the information contained on this site.
If you would like to continue, please click the “Continue” button below. If you
would like to return to our website without opening the third-party link, please
click the “Cancel” link below.”

Our Privacy and Security policies do not extend to any third-party linked sites therefore we are not responsible for the contents of, updates to, or privacy/security practices of these third parties, which may differ from ours.

Geolocation Tracking 

Our services may enable access to third party services and web sites, including GPS locator websites, such as Google, that allow you to find a branch (collectively and individually, "Services"). Use of the
Services may require Internet access and that you accept additional terms of service. You can choose to disable your location feature through your app but doing so will result in you not receiving any information that require a location.

Adopted by the Board of Directors: 1/11/2023
Last Revision: 1/11/2023
Approved by the Board of Directors: 1/11/2023