EFFECTIVE DATE: 3-10-2021
you provide or personal information we obtain when you access or use our website or other online or mobile services or applications (each a “Site” and collectively “Sites”). For purposes of this Policy, (i) personal information
includes "personal data" and “non-public personal information” and similar terms as defined under applicable federal and state privacy laws covering consumer and personal information and (i) “user(s)” means anyone accessing
or using our Sites. We will provide updates to this Policy from time to time at minimum annually via email or online communication. The updates will be effective as of the “Effective Date” stated at the beginning of this Policy.
We are not required to provide you with advance notice of any updates although we may do so such as providing a prominent notice of changes as we determine necessary. We recommend that you visit this Policy regularly to keep apprised of any updates.
What Information is Collected
Depending on how you use a Site and the services you choose to use on a Site, we may collect the information below:
- Information You Provide to Us:
- We collect information you enter on our Sites, or that you give us in any other way. This includes personal information that identifies who you are such as your real name, any alias you may use, your street address, email address, telephone number,
mobile phone number, unique personal identifiers and your credit union employer or affiliation.
- We collect your credit card and debit card account numbers you enter on our Sites or that you ask us to enter for you when you purchase our services or make contributions using our Site.
- You can choose not to provide certain information, but you may not be able to take advantage of the Site or its features or our services.
- Information We Receive From Third Parties and Other Sources
We collect information about you from “third parties” such as service providers and consumer data companies that provide services to us including to help us prevent fraud,
market products and services, conduct human resources management activities, and otherwise support our daily business activities. We also collect information about you from CUSOs, member credit unions, credit union leagues and other credit
union affiliated organizations and other companies with which we do business or companies in which we have invested.
- Information Automatically Collected
When you access, visit or use our Sites or services or conduct transactions on our Sites, we automatically collect certain information including:
- Basic information about your visits and use of our Sites such as the time of your visit, pages you browse and searches you conduct when you visit our Sites.
- Transaction information including the date and time and the online events you register or pay for and the products and services your purchase and contributions you make through our Sites, including dollar amounts paid or contributed.
- Information about the device you use to access our Sites and transactions you conduct at our Sites, including the type of browser you use, hardware model, operating system and app version, mobile network information, IP address, unique device
identifiers, access times, pages viewed, items placed in your cart, links clicked, browsing behavior, and referring URL (the webpage you visited before navigating to our Sites).
- In accordance with your device permissions, we may collect information about the precise location of your device. We may also collect information about your approximate location each time you access our Sites.
- Information Collected by Cookies and other “Tracking Technologies”
We and our third-party service providers may use “cookies”, clear GIFs (also known as web beacons, web bugs or pixel tags), and other tracking technologies
to collect information about you and your interaction with our Sites including information about your browsing behavior, purchase behavior and other engagement with our Sites. “Cookies” are pieces of information that are transferred
to your computer from a web server. Most browsers are set up to accept cookies by default, but you can usually change your browser settings to have your browser notify you when you receive a new cookie or to remove or reject cookies.
We do not track customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. Third parties that have content embedded on our websites such as a social feature or a posting/copy
links may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific website from a certain IP address. Third parties cannot collect any other personally identifiable information from our websites
unless you provide it to them directly.
How and When the Information is Used
The information we collect is used to provide, maintain and improve our services and interactions with you. We use the information for conducting transactions and providing services you request and administering our business activities. For example,
we use the information we collect for:
- Credit and Debit Card Transactions -- We use the account number and information you provide only to conduct the specific transaction you request.
- Registration for events such as conferences and webinars or to complete forms on our Sites such as for making contributions through our Sites.
- Business Operations – Activities performed for the benefit of Cornerstone, credit union members, employees, individuals, or others. This includes events, online activities, online sales and contributions, promotions, verifying individuals
or their purchases, business analytics, marketing, etc.
- Commercial Operations – Activities that promote the growth and success of Cornerstone such as credit union and member promotions and sales of products and other activities that promote the financial well-being of Cornerstone and its member credit
- Quality Control – Activities to prevent mistakes and avoiding problems when delivering products or services to member credit unions or collecting contributions.
- Security – Activities relating to ensuring that all information systems are functional and secure, detecting and preventing malicious and illegal activities that put Cornerstone at risk.
- Systems Maintenance – Maintaining system operations and finding and repairing malfunctions that impair existing or intended Cornerstone system operations particularly in the nature of IT, human resources and accounting activities for Cornerstone.
- Audit & Compliance – Actions that maintain Cornerstone policies and procedures or its compliance with applicable laws and regulations.
- Employment Activities – Activities related to human resource management.
- We may use the information to notify you about changes to our Site, industry announcements, new services, or special offers.
Information is stored for a period of three years.
Sharing of Information
Information about our users is important to us. We may share information we collect with our affiliates including, without limitation. We may share information we collect with our affiliates and partners with whom we collaborate to provide certain products
- CUSOs and credit union leagues for sales of our and our affiliates products and services
- Third party companies in connection with routine or required reporting, including consumer reporting agencies and other parties.
- Third party companies that enable individuals to conduct transactions online and via mobile devices.
- Government agencies as required by laws and regulations.
- Third party companies to whom you provide personal information as part of providing products and services, completing transactions, supporting operations, or business management and development.
- Third party companies, including service providers, to whom you provide personal information to support human resource activities and workforce management.
Selling of Personal Information
We do not sell any personal information to any outside third party without first receiving that user's permission or unless required by law.
None of our Sites provide services or sell products to children under the age of 18.If you are under 18, you may use our Sites only with the involvement of a parent or guardian.
How We Protect Your Information
The privacy and protection of your information is important to us. Except as stated in this Policy or as otherwise required or permitted by law, we do not make any personal information available to third parties without your permission. Your access to
some services and content is password protected. We advise that you do not disclose your password to anyone. In addition, we recommend you sign out of password-protected services at the end of every session.
Methods We Use to Protect Your Information
We use security software to protect the confidentiality of your personal information. In addition, our business practices are reviewed periodically for compliance with policies and procedures governing the security and confidentiality of our information.
Our business practices limit employee access to confidential information including your personal information and limit the use and disclosure of confidential information and personal information to authorized persons.
How You Can Access Your Information
You can request access to or modify all your personal information by sending an email to the VP Marketing & Communications at email@example.com or by calling 469-486-6471.