OnPath Credit Union

OnPath Federal Credit Union has created this Internet Privacy Disclosure in order to demonstrate our commitment to privacy. The following discloses our information gathering and dissemination practices for this website, https://BeOnPath.org (the “Site”). For our policy on data collected through your use of our services, including in-person banking, please see our Privacy Policy.

Please review this Internet Privacy Disclosure carefully. By using this Site, you accept the terms of this Internet Privacy Disclosure. Additionally, by using this Site you consent to our collection, use, disclosure and retention of your information as described in this Internet Privacy Disclosure.

The Effective Date of this Internet Privacy Disclosure is set forth at the bottom of this Internet Privacy Disclosure. Your continued use of the Site after the Effective Date constitutes your acceptance of the amended Internet Privacy Disclosure. Any amended Internet Privacy Disclosure will be published on this page and supersedes all previous versions. Please check back periodically, and especially before you provide any personally identifiable information.

Data Processing of Usage Data

When you access our Site, the following general technical information is automatically recorded: the type of web browser used, the operating system used, your IP address, the domain name of your internet service provider, your interactions with this Site and other similar information.

 Data Processing of Personal Information

If you are requested to provide Personal Information to use our financial and banking services, that Personal Information will be maintained and disclosed in accordance with state and federal law, including the Gramm-Leach-Bliley Act.

 Data Processing Location

Any Personal Information collected about visitors through the Site is processed in the United States by us or by a party acting on our behalf. When you provide Personal Information to us through the Site, you consent to the processing of your data in the United States. The Site is hosted in the United States.

We may use the information we collect for any of the following purposes:

• to provide the Site to you;
• to operate, improve and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
• for customer service, security, to detect fraud or illegal activities, or for archival and backup purposes in connection with the Site;
• to communicate with users;
• to better understand how users access and use the Site, for the purposes of trying to improve the Site and to respond to user preferences, including language and location customization, personalized help and instructions, or other responses to users' usage of the Site;
• to help us develop our new products and services and improve our existing products and services; and
• to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Site.

Please note that, in order to provide you with a better experience and to improve the Site, information collected through the Site may be used in an aggregated or individualized manner. 

How We Share and Disclose Your Information – We do not share any of the anonymized data we collect with any third party vendors.  We may share in cases of legal purposes, aggregated form, or in case of corporate changes such as mergers.

 For legal purposes. We also may share information that we collect from users, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share Personal Information as required to pursue available remedies or limit damages we may sustain.

In aggregated form. We may share Personal Information about you in an aggregated form—that is, in a statistical or summary form that does not include any personal identifiers—with third parties in order to discover and reveal trends about how users like you interact with our services.

During corporate changes. We may transfer information, including your Personal Information, in connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify users before your information is transferred or becomes

Social Media Features
Our Site includes social media plug-ins which are interactive mini programs that run on our Site. These features may allow the third parties that offer the features to collect information such as your IP address, which page you are visiting on our Site, and other data. Social media features are hosted by a third party. Your interactions with these features are governed by the privacy statement of the company providing it. Our Site is not sponsored or endorsed by LinkedIn, Facebook, Twitter, Instagram or YouTube or other third-party websites, which are trademarked and owned by third parties and not by us.

Links to Other Sites; Transactions with Third Parties (SEO backlinks)
The Site may contain links to other sites that are not owned or controlled by OnPath Federal Credit Union. Please be aware that we are not responsible for the privacy practices of these other sites. We encourage you to review the privacy policies and statements of other sites to understand their information practices. This Privacy Policy applies only to information collected by our Site.

Analytics
The Site uses the following third-party analytics services: Google Analytics, Crazy Egg, Matomo Analytics

 For more information about Google analytic cookies, please see Google’s help pages and privacy policy: Google Privacy Policy: http://www.google.com/intl/en/policies/privacy/;
Google Analytics Help: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

We provide information to Matomo Analytics in order to discover trends about how users like you interact with our website and online applications. The information provided is anonymized via a randomly generated user ID every time your device access an online application. No personal information is ever shared or processed.

Crazy Egg analytics determine which way users interact with specific landing pages by creating heat maps of clicks and interactions. The user information is anonymized via a randomly generated user ID and no personal information is ever shared or processed.

Simpli.fi

We provide information to Simpli.fi in order to facilitate advertising services. To control what data Simpli.fi refers to its advertising partners please go to Simpli.fi Ad Choices page [https://optout.simpli.fi/opt-out]. You may also opt out of targeted ads from specific third-party vendors by visiting the Digital Advertising Alliance’s Opt-Out page at http://optout.aboutads.info/#!/

The Site is not intended for use by children. If you are under the age of majority in your place of residence, you may use the Site only with the consent of or under the supervision of your parent or legal guardian.

Consistent with the requirements of the Children's Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent's verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Site and subsequently we will delete that information.

OnPath Federal Credit Union takes appropriate steps to protect your information as you transmit your information from your computer to our site and to protect this information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should remember that no Internet transmission is ever 100% secure or error-free

We, along with the service providers that help us provide the Site, use “cookies”, which are small computer files sent to or accessed from your web browser or your device that contain information about your computer, such as a user ID, user settings, browsing history and activities conducted while using the Site. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier.

The Site may use data collection tools to collect information from the device used to access the Site, such as operating system type, browser type, domain and other system settings, as well as the operating system used and the country and time zone in which the computer or device is located.

Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org.

By using this Site you consent to have these Cookies installed on your device. Cookies may be cleared manually within your browser’s settings. To see your specific browser’s instructions on how to clear Cookies, please follow the appropriate link below:

Chrome: https://support.google.com/accounts/answer/9098093

Edge: https://support.microsoft.com/en-us/help/4027947/windows-delete-cookies

Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

Opera: https://www.opera.com/help/tutorials/security/cookies/

Safari: https://support.apple.com/guide/safari/clear-your-browsing-history-sfri47acf5d6/mac

Although users are not required to accept cookies, blocking or rejecting them may prevent access to some features available through the Services. This site ignores “Do Not Track” browser settings. 

It is important to us that you can access and review the Personal Information we have about you and make corrections to it or delete it, as necessary. 

To the extent that OnPath Federal Credit Union has information related to California consumers not regulated pursuant to the Gramm-Leach-Billy Act, California consumers have the right to request and receive (1) the categories of personal information OnPath Federal Credit Union has collected about that consumer; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purposes for collecting or selling personal information; (4) the categories of this parties with whom OnPath Federal Credit Union shares information and (5) the specific pieces of personal information OnPath Federal Credit Union has collected about that consumer. 

You likewise have the right to the correction or deletion of any of the personal data collected by us on you which might be incomplete, incorrect or outdated. We take care at all times to ensure that your data are only processed if your consent has been given as required. The deletion of your personal data takes place if you revoke your consent, if processing of the personal data is no longer necessary to fulfilling the purpose for which it was originally stored, or if the personal data is processed unlawfully.

OnPath Federal Credit Union does not discriminate in any way against an individual exercising his or her rights under any relevant data privacy statute or regulation, including the California Consumer Privacy Act.

If you have any questions about your Personal Information, including making a request pursuant to the California Consumer Privacy Act, please contact us by phone at (800)482-1314 or by mail to OnPath Federal Credit Union, Attention: Marketing Department.