Disclosures

ONLINE PRIVACY POLICY

4/1/2025

Our commitment to Privacy:

This Online Privacy Policy was developed as part of our commitment to combine the highest-quality services with the highest level of integrity in dealing with our clients and visitors. The Policy is designed to assist you in understanding how we collect, use and safeguard the personal information you provide to us and to assist you in making informed decisions when using our site and services. This Online Privacy Policy may be updated from time to time so that we can keep you updated as to our data privacy practices. If we make any material changes to our privacy practices the Online Privacy Policy will be updated by posting the revised version of this Notice on the Sevenfold Federal Credit Union website under the Privacy Notice link on the website homepage. The updated Online Privacy Policy is effective as of the date listed at the top of this document. By accessing any of our products, services, websites or mobile applications after this date you agree to the terms of our Privacy Notice as of the last effective date.

What Information Do We Collect?

When you visit our Website, you may provide us with two types of information: personal information you knowingly choose to disclose that is collected on an individual basis and Website use information collected on an aggregate basis as you and others browse our Website.

1. PERSONAL INFORMATION YOU CHOOSE TO PROVIDE. If you choose to inquire about our services, you may need to give personal information. For example, you may be asked to provide the following information:

A. Name
B. Mailing address
C. Email address
D. Home and business phone number

Email Information

If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.

2. WEBSITE USE INFORMATION. Similar to other commercial websites, our website utilizes web server logs to collect information about how our website is used. Information gathered through web server logs may include the date and time of visits, the pages viewed, time spent at our website, and the websites visited just before and just after our website. This information is collected on an aggregate basis. None of this information is associated with you as an individual.

Children’s Information. Only persons that are the age of majority in your jurisdiction or older have permission to access our website or mobile applications. We recognize a special obligation to protect personal information obtained from young children. Our website is designed and intended for adults and is not of likely interest to children. The forms on our Site are capable, however, of collecting online information from children under the age of 13 who furnish it without prior parental consent. Upon discovery that any such information has been supplied by children under the age of 13, we will disregard and delete that information. We urge parents to instruct their children to never give out their real names, addresses, or phone numbers without their permission when online.

Information Sent To Us By Your Browser. Like most commercial websites, we collect information that is sent to us automatically by your web browser when you access our website. This information typically includes the IP address of your Internet service provider, the type of your operating system, and the type of your browser. The information we receive depends on the settings on your web browser. Please check your browser if you want to learn what information your browser sends or how to change your settings. We use this information to create statistics that help us improve our website and make it more compatible with the technology used by our visitors. The information provided by your browser does not identify you personally. However, we may review our server logs for security purposes, such as detecting intrusions into our network. If we suspect criminal activity, we might share our server logs – which contain visitors’ IP addresses – with the appropriate investigative authorities who could use that information to trace and identify individuals. In addition, if you access our website through an e-mail we have sent you, we may link the information provided by your browser to information in our records that identifies you personally.

Our Websites and e-mails may contain small electronic files known as beacons (also referred to as web beacons, clear GIFs, pixel tags and single-pixel GIFs) that permit us to, for example, to count users who have visited those pages or opened an e-mail and for other website-related statistics. Beacons in e-mail marketing campaigns allow us to track your responses and your interests in our content, offerings and web pages. You may use the tools in your device to disable these technologies as well.

Information Collected Using “Cookies”. Like many commercial websites, we use “cookies.” A cookie is a small text file that is placed on your hard disk by a web server. Cookies cannot be used to install computer programs or deliver viruses to your computer. We may use two types of cookies – “session cookies” and “persistent cookies.” We may use “session cookies” to assign a randomly-generated unique identification number to your computer. A session cookie expires after you close your browser. We use session cookies to collect information about the ways visitors use our website– which pages they visit, which links they use, and how long they stay on each page. We analyze this information, known as “click-through data,” to better understand our visitors’ interests and needs, and to improve the content and functionality of our Website. We may also use “persistent cookies.” These cookies do not expire when you close your browser, but stay on your computer until they expire or you delete them. Each time you visit our website, our web server will recognize your cookie. By assigning your computer a persistent, unique identifier, we’re able to create a database of your previous choices and preferences. In situations where these choices or preferences need to be collected again, they can be provided by us automatically, saving you time and effort. Assigning your computer a persistent, unique identifier also helps us keep a more accurate account of how many people visit our website, how often they return, how their use of our website may vary over time, and the effectiveness of our promotional efforts. If you access our website through an e-mail we have sent you or you’ve created a “user identity” during one of your visits, we may link the information provided by our cookies to information in our records that identifies you personally.

Log Files. We may use technologies that automatically collect information when you visit our sites, view our advertisements, or use our products or services. This browser data may include information such as your IP address (or other unique device identifier, including one that we may assign); certain details about your browser, operating system, and hardware; your location, if available; the URL that referred you to our sites; your activities on our site, including your preferences; and other logging information, such as the date and time of your visit. We also use web server logs to collect and store information about site usage. We may use this information for fraud detection and prevention, security, and to ensure our sites function properly.

We may use third-party analytics services, like Google Analytics and Google Tag Manager, to collect, monitor and analyze visitor data (such as Browser Log Data, cookies and other tracking data), and trends for marketing optimization and to increase the functionality of our website and mobile applications. These services may track details about your online activities over time and across different websites. These services may also allow us and others to provide you with targeted advertisements or other content that you may be interested in based on your online activities.

The Google Analytics service tracks and reports website traffic and provides us insight into behavior information relating to visitor age, gender, and interests. Google Analytics Demographics and Interest Reporting give us insight into behavior to help us understand browsing behavior and give you a better experience when you visit our website. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings.

These third-party services have their own privacy policies addressing how they use such information. If you want to prevent your data from being used by Google Analytics, you may wish to take advantage of Google Analytics’ currently available opt-outs for the web. We use Google Tag Manager to capture certain non-individually identifiable customer traffic data, including: time spent on page, pdf file downloads, video activity (plays, pauses, percent of video watched, etc.), scroll depth (how far down a webpage a user scrolls), and social actions taken on a website (shares and outbound links to social channels).

If you would like to learn more about targeted ads that may be based on your online activities, and the choices that you may exercise for certain sites and advertisers, you may wish to visit the

Network Advertising Initiative at www.networkadvertising.org, or the Digital Advertising Alliance at www.digitaladvertisingalliance.org.

3. RIGHT OF CHOICE: HOW DO WE RESPECT YOUR PRIVACY CHOICES? If you no longer wish to receive our e-mail communications, follow the unsubscribe instructions on our newsletter. These e-mails are sent through our email system. The company maintains an opt-out list to prevent us from sending e-mails to those addresses.

4. EXTERNAL TRANSFER: HOW DO WE SHARE YOUR INFORMATION? Depending on how you’ve interacted with us in the past, and for what purpose, we may share your information in the ways described below:

Third-Party Service Providers. We may use other companies to provide services to our business and clients, and fulfill your requests. For example, we may share information with our underwriters or use subcontractors for consulting and administrative tasks. We confirm that our service providers are properly protecting the privacy and security of your information.

Other Limited Circumstances. There are other limited circumstances in which we may share your personal information with third parties. For example, we may disclose your personal information when we, in good faith, believe disclosure is appropriate to comply with the law or a regulatory requirement or to comply with a subpoena or court order; to prevent or investigate a possible crime, such as fraud or identity theft; to enforce a contract; to protect the rights, property or safety of Sevenfold Federal Credit Union, LLC or a third party; or to protect your vital interests. In addition, your personal information may be transferred to another company that has acquired the stock or all or part of the assets of Sevenfold Federal Credit Union; for example, as the result of a sale, merger, reorganization, dissolution, or liquidation. If such a transfer occurs, the acquiring company’s use of your personal information will still be subject to this Policy and the privacy preferences you have expressed to us.

We will not otherwise share your personal information with Affiliates, service providers, or other third parties for unknown or unrelated purposes.

Do Not Track

Our websites and applications may, from time to time, collect information about your online activities, over time and across our different websites and applications. When you use our websites and applications, third parties may also collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Websites do not currently change the way they operate based upon detection of a “Do Not Track” or similar signal.

How Do We Use the Information That You Provide to Us?

Broadly speaking, we use personal information for purposes of administering our business activities, providing customer service and making available other products and services to our customers and prospective customers.

Sharing Information

We do not share your personal information with any affiliates, strategic partners, or anyone else. Should this policy change, you will be notified and given the opportunity to remove your personal information.

Notice of New Services and Changes

Occasionally, we may use the information we collect to notify you about important changes to our website, new services and special offers we think you will find valuable. You will be given the opportunity to notify us of your desire not to receive these offers by clicking on a response box when you receive such an offer.

How Do We Protect Your Information?

Information Security. We utilize encryption/security software to safeguard the confidentiality of personal information we collect from unauthorized access or disclosure and accidental loss, alteration or destruction. We reasonably restrict access to nonpublic personal information to those individuals and entities who need to know that information to provide the products or services which we sell. We will use our best reasonable efforts to train and oversee our employees and agents to ensure that your information will be handled responsibly and in accordance with this Privacy Policy. We currently maintain physical, electronic, and procedural safeguards that reasonably guard nonpublic personal, consumer, and lender information.

Evaluation of Information Protection Practices.

Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the security, confidentiality and quality of our information.

Employee Access, Training and Expectations.

Our corporate values, ethical standards, policies and practices are committed to the protection of customer information. In general, our business practices limit employee access to confidential information, and limit the use and disclosure of such information to authorized persons, processes and transactions.

Retention

We keep your information for as long as necessary in accordance with the purpose for which it was collected, our business needs, and our legal and regulatory obligations. If we dispose of your information, we will do so in a way that is secure and appropriate to nature of the information subject to disposal.

Accessibility

We are committed to making our content accessible and user friendly to everyone. To request a copy of this Privacy Policy in an alternative format, please contact us at the information provided below.

What About Legally Compelled Disclosure of Information?

We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights.

What About Other Websites Linked to Our Website?

Our website or mobile applications may contain links to other websites or internet resources that are not operated by us. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party websites or services. If you click on a third-party link, you will be directed to that third-party’s website. We strongly advise you to review the privacy policy and terms of use of every website you visit. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our website.

Please remember that when you use a link to go from our website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites that have a link on our website, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.

Your Consent

By using our website you consent to our collection and use of your personal information as described in this Privacy Policy. If we change our privacy policies and procedures, we will post those changes on our website to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it.

Thank you for allowing us to serve you. We value your business and are committed to protecting your privacy. We hope you view our company as your most trusted adviser and we will work to continue earning your trust and respect. Please call us if you have any question or if we can be of further service.

YOUR CONTINUED USE, ACCESS, OR INTERACTION WITH THE APPLICATIONS, WEBSITES, OR PRODUCTS, OR YOUR CONTINUED COMMUNICATIONS WITH US AFTER THE UPDATED POLICY HAS BEEN POSTED WILL REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY.

 

SMS MESSAGING POLICY

General

When you opt-in to the service, we will send you a message to confirm your signup.

By opting into messages, you agree to receive recurring automated marketing and informational text messages from Sevenfold Federal Credit Union (SFCU) and others texting on its behalf. Automated messages may be sent using an automatic telephone dialing system to the mobile telephone number you provided when signing up or any other number that you designate. You are also authorizing SFCU to send you account-related text messages, account verification messages, account alerts, and OLB Multi-Factor Authentication messages. By doing so, you are accepting the following terms and conditions.

Message frequency varies, and additional mobile messages may be sent periodically based on your interaction with SFCU. SFCU reserves the right to alter the frequency of messages sent at any time to increase or decrease the total number of sent messages. SFCU also reserves the right to change the short code or phone number where messages are sent.

Message and data rates may apply to each SMS sent or received, in accordance with your mobile telephone service plan. If you have any questions about your text plan or data plan, it is best to contact your wireless provider. Your wireless provider is not liable for delayed or undelivered messages.

Your consent to receive marketing messages is not a condition of purchase.

You understand the text messages we send may be seen by anyone with access to your phone. Accordingly, you should take steps to safeguard your phone and your text messages if you want them to remain private. NO CONFIDENTIAL INFORMATION SHOULD BE SENT VIA TEXT MESSAGE. Please notify us immediately if you change mobile numbers or plan to provide your phone to another person.

Carriers, Delivery, and Access

Mobile access and delivery of messages is not guaranteed and SFCU is not responsible for any issues related to network failures. You also agree to indemnify us for all claims, expenses, and damages related to or caused in whole or in part by your failure to notify us if you change your telephone number, including but not limited to, all claims, expenses, and damages related to or arising under the Telephone Consumer Protection Act of 1991 (TCPA), as amended from time to time. Carriers are not liable for delayed or undelivered messages.

Cancellation

You can cancel any time by texting “STOP”. After you send the SMS message “STOP”, we will send you a message to confirm that you have been unsubscribed and no more messages will be

sent unless you opt-in again. If you would like to receive messages from SFCU again, just sign up as you did the first time and SFCU will start sending messages to you again.

Info

Text “HELP” at any time and we will respond with instructions on how to unsubscribe. For support regarding our services, email us at [email protected].

Transfer of Number

You agree that before changing your mobile number or transferring your mobile number to another individual, you will either reply “STOP” from the original number or notify us of your old number at [email protected]. The duty to inform us based on the above events is a condition of using this service to receive messages.

Privacy

Your privacy is important to us. Any personal information collected through the SMS service will be used in accordance with our Privacy Policy. If you have any questions about your data or our privacy practices, you may access our Privacy Policy by visiting our website.

Messaging Terms Changes

We reserve the right to change or terminate our messaging program at any time, with or without notice. We also reserve the right to update these Messaging Terms at any time, with or without notice. Such changes will be effective immediately upon posting to our website. You agree to review the Text (SMS) Messaging Policy periodically to ensure that you are aware of any changes. Your continued enrollment following such changes shall constitute your acceptance of such changes.