WHAT DOES First Financial Credit Union DO WITH YOUR PERSONAL INFORMATION?
|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
|How?||All financial companies need to share members’ personal information to run their everyday
business. In the section below, we list the reasons financial companies can share their members’
personal information; the reasons First Financial Credit Union chooses to share; and whether you
can limit this sharing.
Sharing Personal Information
|Reasons we can share personal information||Does First Financial Credit Union 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
|For our marketing purpose — |
to offer our products and services to you
|For joint marketing with other financial companies||Yes||No|
|For our affiliates’ everyday business purposes — |
information about your transactions and experiences
|No||We don’t share|
|For our affiliates’ everyday business purposes — |
information about your creditworthiness
|No||We don’t share|
|For nonaffiliates to market to you||No||We don’t share|
Limit Our Sharing
|To limit our sharing||Call 773-565-2000|
|Questions?||Call 773-565-2000 or go to firstfcu.org|
Who we are
|Who is providing this notice?||First Financial Credit Union|
What we do
|How does First Financial Credit Union 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 First Financial Credit Union 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
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.
|Affiliates||Companies related by common ownership or control. They can be financial and
First Financial Credit Union has no affiliates.
|Nonaffiliates||Companies not related by common ownership or control. They can be financial and
First Financial Credit Union does not share with our nonaffiliates so they can
market to you.
|Joint marketing||A formal agreement between nonaffiliated financial companies that together market
financial products or services to you.
Our joint marketing partners include Enterprise Car Sales and insurance
Effective Date: May 1, 2023
Scope and Overview
This policy outlines how First Financial Credit Union, its vendors, and/or the licensor of the First Financial Credit Union’s 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 First Financial Credit Union, its vendors, and/or the licensor of the First Financial Credit Union’s consumer verification software collect, capture, or otherwise obtain biometric data relating to a consumer, First Financial Credit Union must first:
Inform each consumer that First Financial Credit Union, its vendors, and/or the licensor of the First Financial Credit Union’s consumer verification software are collecting, capturing, or otherwise obtaining the employee’s biometric data, and that the First Financial Credit Union is providing such biometric data to its vendors and the licensor of the First Financial Credit Union’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 First Financial Credit Union, 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 First Financial Credit Union to provide such biometric data to its vendors and the licensor of the First Financial Credit Union’s consumer verification software.
First Financial Credit Union, its vendors, and/or the licensor of the First Financial Credit Union’s consumer verification software will not sell, lease, trade, or otherwise profit from employees’ biometric data; provided, however, that the First Financial Credit Union’s vendors and the licensor of the First Financial Credit Union’s consumer verification software may be paid for products or services used by First Financial Credit Union 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
First Financial Credit Union, its vendors, and/or the licensor of First Financial Credit Union’s consumer verification software collect, store, and use biometric data solely for identity verification and fraud prevention purposes.
First Financial Credit Union will not disclose or disseminate any biometric data to anyone other than its vendors and the licensor of the First Financial Credit Union’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.
First Financial Credit Union 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 First Financial Credit Union 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.
First Financial Credit Union shall retain consumer biometric data only until, and shall request that its vendors and the licensor of First Financial Credit Union’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.
If you have any questions about our use, storage, or security of your biometric data you can contact us at: firstname.lastname@example.org.
BIOMETRIC INFORMATION CONSUMER CONSENT