EFN-PRIVACY-POLICY

What does encurage financial network (EFN) do with your personal information?

Facts
Why?Financial companies choose how they share your personal information. Federal law gives
consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we
collect, share, and protect your personal information. Please read this notice carefully to understand
what we do.
What?The types of personal information we collect and share depend on the product or service you have
with us. This information can include:
 Social Security number and account balances
 credit history and credit scores
 income and transaction history
When you are no longer our member, we continue to share your information as described in this
notice.
How?The types of personal information we collect and share depend on the product or service you have
with us. This information can include:
 Social Security number and account balances
 credit history and credit scores
 income and transaction history
When you are no longer our member, we continue to share your information as described in this
notice.

encurage financial network Sharing Personal Information

Reasons we can share personal informationDoes encurage financial network share?Can you limit this sharing?
For our everyday business purpose —
such as to process your transactions, maintain your
account(s), respond to court orders and legal
investigations, or to report to credit bureaus
YesNo
For our marketing purpose —
to offer our products and services to you
YesYes
For joint marketing with other financial companiesYesYes
For our affiliates’ everyday business purposes —
information about your transactions and experiences
YesNo
For our affiliates’ everyday business purposes —
information about your creditworthiness
NoWe don’t share
For nonaffiliates to market to youNoWe don’t share

encurage financial network Limit Our Sharing

To limit our sharingCall 773-565-2000
Questions?Call 773-565-2000 or go to firstfcu.org

encurage financial network who we are

Who is providing this notice?encurage financial network

encurage financial network What we do

How does encurage financial network protect my personal information?To protect your personal information from unauthorized access and use, we use
security measures that comply with federal law. These measures include computer
safeguards and secured files and buildings.
How does encurage financial network collect my personal information?We collect your personal information, for example, when you
 open an account or show your government-issued ID
 apply for financing or give us your contact information
 show us your driver’s license
We also collect your personal information from others, such as credit bureaus,
affiliates, or other companies.
Why can’t I limit all sharing?Federal law gives you the right to limit only
 sharing for affiliates’ everyday business purposes – information about your
creditworthiness
 affiliates from using your information to market to you
 sharing for nonaffiliates to market to you
State law and individual companies may give you additional rights to limit sharing.

Copy of Definitions

AffiliatesCompanies related by common ownership or control. They can be financial and
nonfinancial companies.
 First Servicing, LLC
 Owners Access, LLC
NonaffiliatesCompanies not related by common ownership or control. They can be financial and
nonfinancial companies.
 Credit Mountain
 Fiserv
 Kasasa

Joint marketingA formal agreement between nonaffiliated financial companies that together market
financial products or services to you.
 Enterprise Car Sales
 TruStage Insurance

Effective
Date:   September 1, 2023

BIOMETRIC INFORMATION PRIVACY POLICY AND CONSENT

Scope and Overview

This policy outlines how encurage financial network, its vendors, and/or the
licensor of the 
encurage financial network consumer verification software
processes biometric data collected from you for identity verification and fraud
prevention purposes. 

Biometric Data Defined

As used in this policy, biometric data includes “biometric identifiers” and
“biometric information”. “Biometric identifier” means a retina or iris scan,
fingerprint, voiceprint, or scan of hand or face geometry. As the term is used
in this policy, the selfie photograph you upload to the software for use in the
biometric algorithm is considered a “biometric identifier.” 
“Biometric information” means any information, regardless of how it is
captured, converted, stored, or shared, based on an individual’s biometric
identifier used to identify an individual.  

Disclosure and Authorization Policy

To the extent that encurage financial network, its vendors, and/or the licensor of
the 
 encurage financial network consumer verification software collect,
capture, or otherwise obtain biometric data relating to a consumer,
 encurage financial network  must first:

Inform each consumer that encurage financial network, its vendors, and/or the
licensor of the 
encurage financial network consumer verification software
are collecting, capturing, or otherwise obtaining the employee’s biometric
data, and that the 
encurage financial network is providing such biometric
data to its vendors and the licensor of the 
 encurage financial network’s 
consumer verification software;
 

Inform the consumer of the specific purpose and length of time for which the
consumer’s biometric data is being collected, stored, and used; and
 

Receive consent by the consumer authorizing encurage financial network, its vendors,
and/or First Financial Credit Union’s consumer verification software to
collect, store, and use the consumer’s biometric data for the specific purposes
disclosed by the First Financial Credit Union, and for
 encurage financial network 
 to provide such biometric data to its vendors and the licensor of the encurage
financial network’
s consumer verification software. 

encurage financial network, its vendors, and/or the licensor of the  encurage
financial network
 consumer verification software will not sell, lease, trade, or
otherwise profit from employees’ biometric data; provided, however, that the
encurage financial network’s vendors and the licensor of the encurage financial
network
’s consumer verification software may be paid for products or services
used by 
encurage financial network that utilize such biometric data. 

This policy is intended to comply with all federal, state, and local laws. 

Purpose for the Collection of Biometric Data

encurage financial network, its vendors, and/or the licensor of  encurage
financial network’
s consumer verification software collect, store, and use
biometric data solely for identity verification and fraud prevention purposes.

Disclosure

encurage financial network will not disclose or disseminate any biometric data to
anyone other than its vendors and the licensor of the
 encurage financial network’s
consumer verification software providing products and services using biometric data
without/unless:
 

First obtaining consumer consent to such disclosure or dissemination; 

The disclosed data completes a financial transaction requested or authorized by the
consumer;

Disclosure is required by law or ordinance; or 

Disclosure is required pursuant to a valid warrant or subpoena issued by a court of
competent jurisdiction.
 

Security

encurage financial network shall use a commercially reasonable standard of care to
store, transmit and protect from disclosure any biometric data collected. Such
storage, transmission, and protection from disclosure shall be performed in a
manner that is the same as or more protective than the manner in which
 encurage
financial network
 stores, transmits and protects from disclosure other
confidential and sensitive information, including personal information that can
be used to uniquely identify an individual or an individual’s account or
property, such as genetic markers, genetic testing information, account
numbers, PINs, driver’s license numbers and social security numbers.
 

Retention

encurage financial networkshall retain consumer biometric data only until, and
shall request that its vendors and the licensor of 
encurage financial network’s
consumer verification software permanently destroy such data when, the first of
the following occurs:

The initial purpose for collecting or obtaining such biometric data has been
satisfied, such as verification of consumer identity;

Request of consumer to destroy the biometric data; or

Within 30 days of consumer’s provisioning of biometric data.

Contact Information

If you have any questions about our use, storage, or security of your biometric data
you can contact us at:
info@firstfcu.org.

BIOMETRIC INFORMATION CONSUMER CONSENT

As outlined in the “Biometric Information Privacy Policy”, I understand and
consent to the collection, use, retention, storage, and/or disclosure or
re-disclosure of data or images from biometric verification technology by
 encurage
financial network
, its vendors, and/or the licensor of the  encurage financial network
consumer verification software.  I acknowledge that I have been given a copy of the
Policy, or that the Policy has been made accessible to me, and I have had an opportunity
to review it and request any additional information concerning the
 encurage financial
network’
s procedures and safeguards for collecting, maintaining, using, disclosing,
sharing, storing, 
and/or destroying this data.