General Policy Statement

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The Credit Union will comply with the Children's Online Privacy Protection Act (COPPA) in the operation on services and its website; and will diligently protect the privacy of children under thirteen and the online collection of data and information from children using its website or service.

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1. APPLICABILITY OF COPPA.

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A. Determination. The Credit Union will comply with COPPA requirements in its operation of a commercial website, or an online service directed to children under thirteen (13) that collects personal information from children; or in its operation of a general audience website and has knowledge that personal information about children under thirteen is being collected.​

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B. Collection. The Credit Union is collecting information if the Credit Union:

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• Requests, prompts, or encourages the submission of information, even if it is optional;​

• Allows information to be made publicly available before the Credit Union takes reasonable measures to delete all or virtually all personal information before postings are public and delete all information from the Credit Union's records; or​

• Passively tracks a child online.

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C. Children's Personal Information. The personal information that may be collected from children can include:

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• Full name

• Home address;

• Geo-location information sufficient to identify a street name and city or town;

• Online contact information;

• Telephone number;

• Social Security number;

• Photo, video, or audio file containing a child's image or voice;

• Persistent identifier that can be used to recognize a user over time and across different sites, including a cookie number, an IP address, a processor or device serial number, or a unique device identifier;

• Any information that allows someone to identify or contact the child; and

• Other data and/or facts that can be tied to individually identifiable information; including:

  • Hobbies;

  • Interested; and

  • Information being collected through cookies and other types of tracking mechanisms.

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2. PRIVACY NOTICE.

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A. Content. The Credit Union's children's online privacy notice will be clearly written, understandable and will contain:

 

• Credit Union's name and contact information (address, telephone number and email address;

• Names of any other operator that may be collecting or maintaining children's personal information;

• Kinds of personal information collected from children;

• How information is collected from children;

  • If the information is collected directly from the child; and/or

  • If the information is collected passively through cookies​​

• How the Credit Union uses the child's personal information it has collected, including the use of audio files and how they are appropriately deleted.

• The parent/guardian's option to agree to the collection and use of their child's information.

• If the information collected from children is disclosed to a third party; and if so: the kinds of business the third party is engaged in; the purpose for collecting the information and how it will be used; and a statement on the third parties agreement to maintain the confidentiality and security of the information.

• The parent/guardian's right to opt-out of sharing the child's information with third parties;

• That the Credit Union will not require children to disclose more information than is reasonably necessary to participate in the Credit Union's website or online service as a condition of participation; and

• The parent/guardian's right to review the child's personal information, ask to have it deleted, and refuse to allow any further collection or use of the child's information.

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B. Placement. The Credit Union will post a link to the Children's Online Privacy Notice on the home page of its website or online service and at each area where it collects information from children.

• The link will be clear and prominent.

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VERIFIABLE PARENTAL CONSENT.

A. Consent Requirement. Before collecting, using or disclosing personal information from a child, the Credit Union will obtain verifiable parent/guardian consent from the child's parent/guardian. The Credit Union will make reasonable efforts (taking into consideration available technology) to ensure that before personal information is collected from a child, a parent/guardian of the child receives notice of the Credit Union's information practices and consent to those practices.

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B. Third Party Consent. The Credit Union will give parents/guardians the option to agree to the collection and use of the child's personal information without agreeing to the disclosure of that information to third parties. The Credit Union does not need to get parental/guardian consent to release information to others who use it solely to provide support for the internal operations of the Credit Union's website or service, including technical support.

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C. Renewed Consent: The Credit Union will send a new notice and request for consent to parents/guardians if there are material changes in the collection, use or disclosure practices to which the parent/guardian had previously agreed.

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D. Exceptions. Prior parent/guardian consent is not required when the Credit Union:

• Collects a child's email address for the purpose of:

  • Providing notice and seeking parent/guardian consent;

  • Responding to a one-time request from a child and then promptly deleting it;

  • Protecting the security or liability of the website or service; or to respond to law enforcement.

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• Collects an audio file with a child's voice when:

  • It is collected solely as a replacement of written words, such as to perform a search or to fulfill a verbal instruction or request, and;

  • The recording is held only for a brief time and only for that purpose (not making any other use of the file before it is destroyed).

  • The audio file exception would not apply when the Credit Union requests information via voice that would otherwise be considered personal information.

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4. PARENT/GUARDIAN INFORMATION REQUEST.

A. Parent/Guardian Request. At a parent/guardian's request, the Credit Union will disclose the general kinds of personal information they collect online from children (for example, name, address, telephone number, email address, hobbies), as well as the specific information collected from their children who visit the Credit Union's website or service.

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B. Parent/Guardian Relationship Verification. The Credit Union will use reasonable procedures to ensure they are dealing with the child's parent/guardian before they provide access to the child's specific information.

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PARENT/GUARDIAN CONSENT REVOCATION.

A. Revocation. At any time, a parent/guardian may revoke his/her consent, refuse to allow the Credit Union to further use or collect their child's personal information, and direct the Credit Union to delete any information the Credit Union may have retained.

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B. Timing. The Credit Union will promptly delete any information it has about a child after a parent/guardian revokes consent for the Credit Union to collect and retain the information.