Effective: March 17, 2021
Tower Federal Credit Union is committed to protecting your privacy and providing you with a positive experience on our website and while using our online services.
What this Statement covers
This Tower Federal Credit Union Online Privacy Statement (“Privacy Statement”) describes how we collect information when you visit or use Tower’s website located at www.towerfcu.org, including its subpages (the “Site”), and when you access and use any of our mobile applications and/or online services (“Online Services”). The Online Services are subject to separate terms and conditions concerning the use of such Online Services. This Privacy Statement also describes how we use and share such information and explains your privacy rights and choices. The Site and our Online Services are intended for a U.S. audience. The terms “Tower,” “we,” “us,” or “our” mean Tower Federal Credit Union. “You” means any individual who visits our Site and/or uses our Online Services.
What this Statement does not cover
This Privacy Statement does not apply to the websites, mobile applications, or services of Tower’s affiliates (e.g. Tower Wealth Management, Tower Title Services). It also does not apply to non-Tower companies, such as our partners or any third-party websites that we link to online through the Site or otherwise. Please review the privacy policies of other websites and services you visit to understand their privacy practices.
Other important resources
Our Privacy Notice applies to information that we collect about individuals who seek, apply for, use, or obtain our financial products and services.
By visiting and/or using our Site and/or any of our Online Services, you agree to the terms and conditions of this Privacy Statement and consent to the use of online tracking technologies as described below.
Collection of Your Personal Information
We collect information in a variety of contexts, including:
- Directly from you. We collect information directly from you, such as when you apply or register for our products and services, use our online banking services or mobile apps, communicate with us, respond to surveys, provide feedback, or enter contests or promotions.
This Privacy Statement applies to information we collect when you access and use Site and/or our Online Services. We may combine that information with information we collect in other contexts, such as from our phone calls and emails with you, from third-party data sources for fraud prevention, or from identity verification sources.
Types of Information Collected
Depending on how you interact online with us, we may collect various types of information. For example, when you sign up for or use a financial product or service online, we may collect:
- Contact or identity data, such as your name, mailing address, email address, phone number, date of birth, government-issued identifier (e.g., Social Security number or driver’s license), citizenship, username and password, and other information that directly identifies you.
- Account-related data, such as member/account number, credit/debit card number, account history, account balances, loan details, vehicle or property information, information about beneficiaries and joint account holders, and other information related to your Tower accounts, applications, or inquiries.
- Transaction data, such as credit/debit card purchases, payment or transaction history, transaction details when you transfer money to or from your Tower accounts, and third-party billing information or statements.
- Demographic data, such as gender, marital status, age, household size/composition, education level, income, occupation, and employment status.
When you browse our website or use our mobile apps, we may also collect:
- Device data, such as your device type, web browser type and version, operating system type and version, photos (e.g., to deposit checks), internet protocol address, mobile network information, general location (e.g., city, state, or country), precise location (e.g., latitude/longitude to find a nearby Tower branch or ATM, or when entering/exiting a specific location), cookie IDs, mobile advertising IDs (e.g., Apple’s IDFA or Google’s Advertising ID), and device IDs (collectively, “Device Data”).
- Online/mobile activity data, such as login data, search history, information about how you use and interact with our Site and/or any of our Online Services or advertising (including content viewed, links clicked, and features used), when and how often you use our Site and/or any of our Online Services, referrer URL, and crash reports (collectively, “Online/Mobile Activity Data”).
- Marketing data, such as your marketing preferences, information about products or services we think you might like, and inferences based on your interactions with us or our partners (e.g., Online/Mobile Activity Data used for targeted advertising).
- Communications data, such as your communication preferences and details or the content of your communications with us (e.g., email and chat messages).
- Survey and research data, such as your responses to questionnaires, surveys, requests for feedback, and research activities.
If you disclose any information relating to other people to us or to our service providers when you visit or use our Site and/or any of our Online Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.
Cookies and Online Tracking Technologies
We and third-party providers acting on our behalf use a variety of online tools and technologies to collect information when you visit or use our Site and/or any of our Online Services, including Device Data and Mobile/Online Activity Data. For example, we use these tools to collect information for debugging, fraud prevention, and other necessary purposes. We also use these to conduct personalization, analytics, and targeted advertising on or through our Site and/or any of our Online Services. We may associate this tracking data with your Tower account (if you have one).
These tools include:
- Server logs. Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to our Site on a particular time and day.
Using Your Personal Information
We use information for various purposes depending on how you interact with us. For example, we may use your information for providing, maintaining, and servicing your accounts; processing transactions and or payments; verifying your identity; detecting and preventing fraud; protecting against security risks; advertising and marketing; conducting analytics and research; improving our products and services; and carrying out legal and business purposes. Our Privacy Notice provides additional information about how we share information we obtain when offering financial products and services.
Sharing Your Personal information
We may share information with service providers with whom we work, such as data processors and companies that help us market products and services to you. When permitted or required by law, we may share information with additional third parties for purposes including response to legal process. Our Privacy Notice provides additional information about how we share information we obtain when offering financial products and services.
Keeping Information Secure
We have an information security program that includes administrative, technical, and physical measures to protect information within our company. If you feel that the security of any data that we hold about you has been compromised, please immediately notify us of the problem by contacting us. Visit our Fraud and Identity Theft Prevention page for more information and tips about how to protect against fraud and identity theft.
Tower will never request sensitive account information through unsolicited phone calls or e-mail messages. If you receive an unsolicited phone call or e-mail message claiming to be from Tower or any other group requesting that you provide your account numbers, Social Security number, personal identification numbers (PINs), passwords, or other confidential information, please do not divulge any information or click on any links. Report the suspected fraudulent activity to the Internet Crime Complaint Center.
Retention of Personal Information
We will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our rights and agreements.
Our Online Services are not directed to children under the age of 13. We also do not knowingly collect personal information from children under 13 through our Site and/or any of our Online Services, and request that children do not provide information to us through our Site and/or any of our Online Services.
Tower Federal Credit Union has official pages on social media services such as Facebook, LinkedIn and YouTube. Any posts you make on our official social media pages — including posts that contain pictures, comments, suggestions, opinions, complaints, or personal information — are available to others who use those pages. Never include sensitive personal, financial, or other confidential information such as your Social Security number, account number, phone number, mailing address, or email address when posting or commenting online. Please refer to the privacy policies of the social media companies hosting social media pages when you interact with them online.
Updates to This Privacy Statement
We may make changes to this Privacy Statement from time to time. The “Effective Date” at the top of this page shows when this Privacy Statement was last revised. Any changes will become effective when we post a revised version of this Privacy Statement on our Site. Your use of our Site and/or any of our Online Services are subject to the terms in the version of this Privacy Statement that is posted on our Site at the time of your visit. We encourage you to review this Privacy Statement periodically to remain informed about how we are protecting and may use and disclose your data.
If you have questions about this Privacy Statement or our privacy practices, please contact us.