Updated 09/22/2020
This California Consumer Privacy Act Disclosure explains how Dupaco Community Credit Union collects, uses, and discloses Personal Information relating to California residents covered by the California Consumer Privacy Act (CCPA). This notice is provided pursuant to the CCPA.
Under the CCPA, ‘Personal Information’ is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. The CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (GLBA).
The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this Disclosure does not apply with respect to information that we collect about California residents who apply for or obtain our financial products and services for business, personal, family, or household purposes. For more information about how we collect, disclose, and secure information relating to members, please refer to our Privacy Notice.
Personal Information We Collect
In the past 12 months, we have collected and disclosed to third parties for our business purposes the following categories of Personal Information relating to California residents covered by this Disclosure:
- Identifiers, such as name, Tax ID, and government-issued identifier;
- Personal Information, such as contact information and financial information
- Protected classifications under California or federal law, such as sex and marital status
- Membership information, such as transaction information and purchase history
- Internet or network activity information, such as browsing history and interactions with our website
- Geolocation data, such as device location and Internet Protocol (IP) location
- Audio, electronic, visual and similar information, such as call and video recordings
- Professional or employment-related information, such as work history and prior employer
- Education information, such as student transcripts; and
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
The categories of sources from whom we collected this Personal Information are:
- Directly from a California resident or the individual’s representatives
- Affiliates, service providers, consumer data resellers and other third parties
- Public record sources (federal, state or local government sources)
- Information from member-directed third parties or institutions representing a member or prospective member
- Information from business members about individuals associated with the business
- Website/mobile app activity/social media
The categories of third parties to whom we disclosed Personal Information for our business purposes described in this Disclosure are:
- Affiliates of Dupaco Community Credit Union
- Vendors and service providers who provide services such as website hosting, data analysis, email delivery, marketing and marketing research activities
- Other third parties who enable members or prospective members to conduct applications and transactions online and via mobile devices
- Partners and third parties who market the credit union and its financial services and products to members and prospective members
- Government agencies as required by laws and regulations
Use of Personal Information
In the past 12 months, we have used Personal Information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:
- Performing services, including providing member service, processing transactions, providing financing, verifying information, providing advertising or marketing services, maintaining or servicing accounts, or similar services.
- Detecting security incidents, and protecting against deceptive and/or fraudulent activity.
- The customization of website and/or advertising content shown.
- Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business.
- Debugging to identify and repair errors that impair existing intended functionality.
- Undertaking internal research for technological development and demonstration.
- Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions).
Disclosure and Sale of Personal Information
Disclosure of Personal Information to Service Providers
In the preceding twelve months, Dupaco has disclosed the following categories of personal information for a business purpose:
- Identifiers, such as name, Tax ID, and government-issued identifier
- Personal Information, such as contact information and financial information
- Protected classifications under California or federal law, such as sex and marital status
- Membership information, such as transaction information and purchase history
- Internet or network activity information, such as browsing history and interactions with our website
- Geolocation data, such as device location and Internet Protocol (IP) location
- Audio, electronic, visual and similar information, such as call and video recordings
- Professional or employment-related information, such as work history and prior employer
- Education information, such as student transcripts; and
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics.
Sale of Personal Information to Service
For purposes of this Disclosure, “sold” means the disclosure of Personal Information to a third party for monetary or other valuable consideration. In the preceding twelve months, Dupaco has “sold” the following categories of Personal Information for a business purpose:
- Identifiers, such as name, Tax ID, and government-issued identifier; and
- Personal Information, such as contact information and financial information.
Do Not Sell My Personal Information: If you are a California resident, you have the right to opt out of the sale of your information by submitting a request by email at service@dupaco.com or by phone at 800-373-7600, ext. 0.
Rights under the CCPA
If you are a California resident, you have the right to:
1) Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- The categories of Personal Information about you that we collected
- The categories of sources from which the Personal Information was collected
- The purpose for collecting Personal Information about you
- The categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
- The specific pieces of Personal Information we collected about you.
2) Request we delete the Personal Information we collected from you unless the CCPA recognizes an exception. In the event that you choose to exercise this right, please note that we may nevertheless retain your Personal Information as permitted under applicable law, including but not limited to the following purposes:
- To provide goods or services within the context of our relationship with you;
- To detect security incidents or other fraudulent or illegal activity;
- To comply with Dupaco Community Credit Union’s legal and regulatory obligations; and
- To enable other uses that are compatible with your expectations or appropriate given the context in which the Personal Information was collected.
3) Be free from unlawful discrimination for exercising your rights under the CCPA.
We will acknowledge receipt of your request within 10 days of the original request.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights.
We will advise you in our response if we are not able to honor your request. We will not provide social security numbers, driver’s license numbers or government-issued identification numbers, financial account numbers or account information, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud, or unreasonable risk to data or systems and network security.
We will work to process all verified requests within 45 days pursuant to the CCPA.
How to Exercise Your Rights
If you are a California resident, you may submit a request by submitting a request by email at service@dupaco.com or by calling us at 800-373-7600, ext. 0.
Requests made on your behalf
When we receive a verifiable request from your “authorized agent,” which is any person or legal entity registered with the California Secretary of State that you have authorized to act on your behalf, we will require:
1) Submission of a written document signed by you with your permission for the authorized agent to submit a verifiable request on your behalf and require the authorized agent to verify its own identity to us; or
2) Your authorized agent to furnish a copy of a power of attorney pursuant to California Probate Code sections 4000 to 4465 and require the authorized agent to verify its own identity to us.
We will deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf and cannot verify their own identity to us.
Questions or Concerns
You may contact us with questions or concerns about this Disclosure and our practices by:
1) Writing us at:
Dupaco Community Credit Union
P.O. Box 179
Dubuque, IA 52004-0179
2) Emailing us at service@dupaco.com
3) Calling us at 800-373-7600, ext. 0
Changes to This California Consumer Privacy Act Disclosure
We may change or update this Disclosure, and changes made will be reflected on this page.
