First Commerce Mobile Privacy NoticeLast Updated: 2/22/24FCCU Mobile Banking App (the “App”) helps you control your credit and/or debit cards through your mobile device, making it easy to manage your finances on the go. The App allows you to:
- get real-time balances for your accounts
- manage your money
- view your transactions and statements
- make transfers
- pay your bills and manage billers
- deposit a check
- receive alerts
- manage cards
This Mobile Banking Privacy Policy, in combination with other relevant privacy notices that we provide to you (e.g., pursuant to financial privacy laws), inform you of the policies and practices regarding the collection, use, and disclosure of any personal information that our service providers and we collect from or about users in connection with the App’s website and mobile application (the “Services”).THE TYPES OF INFORMATION WE COLLECT IN THE APPThrough your use of the Services, we may collect personal information from you in the following ways:
- Personal Information You Provide to Us for online banking use
When you create an account, we may collect personal information from you, such as your first and last name, address, e-mail, telephone number, and social security number. We will collect the financial and transaction information necessary to provide you with the Services, including account numbers, payment card expiration date, payment card identification, verification numbers, and transaction and payment history.
If you provide feedback or contact us via email, we will collect your name and email address and any other content included in the email to send you a reply.
We also collect other types of personal information that you provide voluntarily, such as any information requested by us if you contact us via email regarding support for the Services.
Zelle Information collected:Zelle is a convenient way to send money to friends, family, and others you trust. When you use Zelle through our mobile banking app, we may collect and share the following information with Zelle’s service providers and the recipient’s financial institution:
Zelle may collect /transmit/sync/stores information about your name, email address, ssn, mobile phone number. This information is necessary to process your transaction securely and efficiently
Zelle may collect /transmit/sync/store information about your transaction, this includes debit cards linked to Zelle account , bank account numbers, and transaction history made through the app , including Zelle transactions.
Zelle stores information about the transaction you make using their services. This includes details such as the amount sent or received, the recipient’s information and the timestamp of the transaction
- Upload Contact List Information
With your explicit consent, Zelle may collect /transmit/sync/store/ access and upload your contact list information to facilitate the Zelle service. This includes contact names, address, phone numbers, and email addresses.
Zelle may collect /transmit/sync/store data about the devices you use to access their service. This can include device identifiers, IP addresses, browser types and operating systems. This information helps ensuring security and providing a personalized user experience. Zelle may collect data bout the device you use to access their service. This can include device identifiers, IP address, browser types .
If you enable location services on your device , Zelle may collect /transmit/sync/store data about your location. This can be used for fraud prevention an to offer location-based services
- Cookies and Tracking Technologies
Like many online services, Zelle may collect /transmit/sync/store cookies and other tracking technologies to gather information about browser behaviors and preferences. This helps in improving their services and targeting advertisements.
Zelle may collect /transmit/sync/store information from user’s communications with their customer support team.
Personal Information Collected from Third Parties.We may collect certain information from identity verification services and consumer reporting agencies, including credit bureaus, in order to provide some of our Services.
Check Deposited Images.Zelle may collect /transmit/sync/store check deposit information when users are using the mobile banking app to deposit a check by capturing an image of the front and back of the check that you capture using the mobile app’s camera. The following information may be captured: Payee name, amount, account number and routing number.
Personal Information Collected Via Technology.Our service providers and we may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications, and other online services, such as:Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns. Local storage technologies, like HTML5 and Flash, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser, in connection with specific applications.Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email was accessed or opened or that certain content was viewed or clicked.
Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect your location information when you use the Services; for example, to provide our ATM/ITM locations. If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device.Google Android Specific Information we are collecting:
- Approximate Location (3 Square Kilometers), Precise Location (less than 3 Square Kilometers)
- Personal Info (Name, Email address, User IDs, Address, Phone Number)
- Financial Info (User payment information, Purchase history, credit score, Other financial info)
- Messages (SMS or MMS, other in-App Messages) Contacts (Contacts)
- App Activity (App Interactions, in-app search history, other actions)
- App info and Performance (Crash logs, Diagnostics, Other App performance data)
- Device or other IDS (Device IDs)
- Contact List Information (With your consent , we may access and upload contact list information
to facilitate features
- Check Deposit Image
In addition, we use the following device features in our application:
PERMISSION | FUNCTION | EXAMPLE |
Camera/image | Allows access to devices camera | Mobile Remote Deposits |
Location | Allows access to location | Maps, Zelle |
Access to External Storage | Allows access to files/media on the device | Secure message Attachments, Zelle |
Contacts | Allows Access to contacts on device | Person to Person Payments Recipient List |
Phone State | Allows access to information about the user’s device for device identification | Statistics & Reporting, Zelle |
Upload Contact List | Allows uploading of your contact list with your consent | Zelle |
HOW WE USE YOUR INFORMATION COLLECTED IN THE APP
General Use.In general, we use your personal information collected through your use of the Services to respond to your requests as submitted through the Services, to provide you the Services you request, and to help serve you better. We use your personal information, in connection with the App, in the following ways: facilitate the creation of, and secure and maintain your account; identify you as a legitimate user in our system; provide improved administration of the Services; provide the Services you request; improve the quality of experience when you interact with the Services; send you administrative e-mail notifications, such as security or support and maintenance advisories; and send surveys, offers, and other promotional materials related to the Services.
Check Deposited Images.Zelle may use the check deposit information and details to deposit transaction and credit the specified account , verify the authenticity of the check and ensure compliance, with our regulatory policies. Zelle may also use the information for record keeping purposes in according with regulatory compliances. Lastly Zelle may also use this information for Customer support if users encounter deposit issue and also fraud prevention in detecting and preventing fraudulent activities related to check deposits.
Zelle Data Usage.In order to facilitate easy and secure transactions, Zelle requests access to your device’s contact list. By granting access, you allow Zelle to display your contacts within the app, making it easier for you to send money to your friends and family. Rest assured that we prioritize the security and privacy of your information, and we will only use this access for the intended purpose of facilitating payments. Your contact information will not be shared with third parties without your explicit consent. By continuing to use Zelle, you consent to the access and use of your contact list for this purpose. You can manage app permissions in your device settings at any time.
Zelle uses your personal information to create and manage your Zelle Account. It helps in verifying your identity, ensuring the transactions are secure and providing personalized services.
Zelle uses the financial data for facilitating money transfers between users. It is used to verify payment methods , process transactions, and maintain accurate records of account balances and transactions history
Zelle uses the transaction information to process payments, reconcile accounts and provide users with you transaction history data. It also helps in detecting and preventing fraudulent activity.
- Uploading Contact List Information
To make sending money easier Zelle may request access to the members device ‘s contact list. If permission granted Zelle will store contact information from the device to help identify and select recipients within the apps settings to receive and send funds.
Zelle uses the device data for security purposes, such as identifying and preventing unauthorized account access. It may also be used to optimize user experience across different device and platforms
Zelle uses location data in help detecting suspicious transactions or unauthorized account access, particularly if a transaction originates from unexpected location.
- Cookies and Tracking Technologies
Zelle uses location cookies and other tracking technologies data to improve the functionality and performance of the Zell website and mobile apps. This data may also be used for analytical purposes to understand how user interact with the service and to delivered targets
Zelle uses communication data to address user inquires , provide customer support, and gather feedback to improve the quality of service.
Compliance and protection.We may use your personal information to: comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities; protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements and internal policies; enforce the terms and conditions that govern the Service; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
Creation of Non-Identifiable Data.The App may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties at our discretion.DISCLOSURE OF YOUR PERSONAL INFORMATIONTo help deliver products, services, and content tailored to your online services and use, we may share aggregated and anonymous information with third parties. We disclose your personal information collected through your use of the Services as described below.
- In Accordance with Our Other Privacy Notices.
Other than as described in this Privacy Policy in connection with the App, this Privacy Policy does not apply to the processing of your information by us or third parties with whom we share information.
- In Accordance with Disclosure of Zelle Data
We will not disclose your contact list information obtained through Zelle integration to third parties for marketing purposes. However, we may share this information with service providers who assists us in operating our mobile application and providing banking services including Zelle. Additionally , we may disclose your information in response to legal request, court orders, or to comply with applicable laws.
Third Party Service Providers.We may share your personal information with third-party or affiliated service providers including Zelle, that perform services for or on behalf of us in providing the App, for the purposes described in this Privacy Policy, including to provide you with the Services; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the Services; to provide technical support; and/or to provide other services to the App.
Authorities and Others.Regardless of any choices you make regarding your personal information, The App may disclose your personal information to law enforcement, government authorities, and private parties for the compliance and protection services described above.LINKS TO OTHER SITESThe App may contain links to third-party websites. When you click on a link to any other website or location, you will leave the App and go to another site. Another entity may collect personal and/or anonymous information from you. The App’s provision of a link to any other website or location is for your convenience. It does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these external websites. We encourage you to read the privacy policy of every website you visit.YOUR CHOICES REGARDING YOUR INFORMATIONYou have several choices regarding the use of information on the Services.
How We Respond to Do Not Track Signals.Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. We currently do not act in response to these signals. When a standard is established, we may revise its policy on responding to these signals.
Access, Update or Correct Your Information.You can access, update or correct your information by changing preferences in your account. For additional requests, please contact us.
Opting Out of Email or SMS Communications.Suppose you have signed-up to receive our email marketing communications. In that case, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email or other electronic communication. Alternatively, you can opt-out of receiving marketing communications by contacting us at the contact information under “Contact Us” below. If you provide your phone number through the Service, we may send you notifications by SMS, such as provide a fraud alert. You may opt-out of SMS communications by unlinking your mobile phone number through the Services.
Opting Out of Location Tracking.If you initially consented to the collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the App. SAFEGUARDS AND RETENTIONWe implement reasonable administrative, technical, and physical measures in an effort to safeguard the information in our custody and control against theft, loss, and unauthorized access, use, modification, and disclosure. Nevertheless, transmission via the internet is not completely secure, and we cannot guarantee the security of your information.A NOTE ABOUT CHILDRENThe Services are not directed towards individuals under the age of 18, and we do not, through the App, intentionally gather personal information about visitors who are under the age of 18 with the exception of the FCCU SmartStart Teen Checking Account product. FCCU SmartStart Teen Checking is available for individuals aged 13-17 years old.If a child under the age of 18 submits personal information to us through the App for any reason besides the FCCU SmartStart Teen Checking Account, we will attempt to delete the personal information of the child under 18 as soon as possible.PRIVACY POLICY UPDATESThis Privacy Policy is subject to occasional revision. We will notify you of any material changes in its collection, use, or disclosure of your personal information by posting a notice on the Services. Any material changes to this Privacy Policy will be effective when posted unless otherwise indicated. If you object to any such changes, please notify the Financial Institution that you wish to deactivate your online account. Continued use of the Services following notice of any such changes shall indicate your acknowledgment of such changes.This Privacy Policy is effective as of the date stated at the top and applies to all users of our online banking mobile application, including those who use the Zelle service. CONTACT USIf you have any questions about this Privacy Policy or The App’s data collection or processing practices, or if you want to report any security violations to The App, please contact The App by email at:
FCCUMemberServices@firstcommercecu.org; or by mail at:
First Commerce CU
P.O. Box 6416
Tallahassee, FL 32314