Privacy Notice
SUMMARY
December, 2023
Information Collected by Royal Credit Union (“Royal”)
- Royal may collect information about you from a variety of sources, including from you directly, from your use of Royal’s financial services, from your communications with Royal team members, from your use of Royal’s websites, virtual chat tools or mobile applications, and from third party sources.
- See Section II (below)
How Royal Uses and Shares Collected Information
- Royal may use information collected from you to provide you with financial services, to provide you with member service, to communicate with you about your Royal account(s), to offer you products or services, and for other purposes.
- Royal may share certain information collected from you (including personal information) with third parties acting on Royal’s behalf (including third party payment card processors), with other financial companies for joint marketing purposes, with credit bureaus, and with other third parties.
- Royal may share aggregated data (which excludes your personal information) with Royal’s business partners and other third parties.
- See Section III (below)
Correcting Personal Information and Opting Out
- You may review and update certain personal information by signing in to online banking, by contacting Royal, or by making the request in person at any of Royal’s branch locations.
- You may opt out of receiving certain communications from Royal, such as communications regarding marketing or promotions, by clicking on the email opt out link.
- See Section IV (below)
- See Section V (below)
Safeguarding Your Information
- Royal is committed to maintaining the security of the data you provide us. However, please note that there is always some risk in transmitting information over the Internet. To learn more about our security practices, visit the Security and Fraud page on Royal’s website.
- See Section VI (below)
California Privacy Rights
- California residents have the right to request that Royal disclose certain information to them about Royal’s collection and the use of their personal information over the past twelve (12) months.
- See Section VII (below)
Tracking and Analytics
- Royal’s websites currently do not respond to “Do Not Track” signals from browsers.
- Royal works with third-party analytics service providers, including but not limited to Google Ads and Twitter Ads, to help better understand how you use Royal’s websites.
- Third parties may collect certain information on third-party websites where Royal advertises; however, Royal does not allow third parties to collect Royal’s users’ personal information on Royal’s websites or through Royal’s online services.
- See Section VIII (below)
Exclusions
- This Privacy Notice does not apply to websites owned by other companies.
- Royal does not seek to collect, nor does Royal knowingly collect information from children under 13.
- If you are located outside of the United States and are using Royal’s financial services, you consent to Royal’s transfer, processing, and storage of your information in the United States.
- See Section IX (below)
Contact Royal
- You may contact Royal by calling 800-341-9911 or by logging in to Online Banking and sending a Secure Message.
- See Section X (below)
Updates to Privacy Notice
- If this Privacy Notice is updated, Royal will note at the top of this page the date that any changes are made or become effective.
- Your inaction or continued use of Royal’s financial services, including access to Royal’s websites or mobile applications, after any such updates or notices indicates that you agree to these changes.
- See Section XI (below)
I. INTRODUCTION
Royal Credit Union (“Royal”) is a Wisconsin chartered credit union. Royal is committed to respecting and protecting the privacy of online visitors to Royal’s websites and its Members. Royal recognizes that individuals need to understand how their privacy is protected, so Royal established the following privacy notice (this “Privacy Notice”).
This Privacy Notice explains what personal information Royal will collect about you from Royal’s websites and mobile applications, both defined below (collectively, the “online services”) as well as from third-party and offline sources. This Privacy Notice also explains how Royal uses, protects, and discloses information to provide you with the online services and other financial services (collectively, the “financial services”).
This Privacy Notice should be read in conjunction with the terms of use that apply to each Royal website, including but not limited to the Website Terms of Use. When you use Royal’s financial services or otherwise provide Royal with your personal information, you consent to Royal’s collection, use, and sharing of the data as described in this Privacy Notice.
Do you have a financial account with Royal (in other words, are you a Member)? Royal uses and shares Members’ personal information in accordance with the Royal’s Privacy Policy.
What does personal information mean? “Personal information” means personally identifiable information, such as your name, email address, telephone number, and account numbers. It does not include aggregated data that does not reveal your identity or anything about you individually. Rather, aggregated data consists of information about a group that includes you. Remember, aggregated data is not considered personal information.
What do Royal websites refer to? These are Royal’s websites that link to this Privacy Notice, including but not limited to rcu.org and rcuonline.org.
What do Royal mobile applications (apps) include? These are Royal’s mobile apps that are available for your mobile device (e.g., phone or tablet), including Royal’s mobile app that allows Members to manage their Royal account(s).
II. INFORMATION COLLECTED BY ROYAL
Why does Royal collect personal information? Royal collects personal information because this information makes it possible for Royal to provide you with the full benefits of the financial services. Royal collects certain information from you, your devices, the applications you use to access the financial services, and from third-party sources so that Royal can provide the financial services to you.
1. CATEGORIES OF INFORMATION THAT ROYAL COLLECTS
In the preceding twelve (12) months, Royal may have collected the following categories of information (please note that some categories overlap):
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Category |
Examples |
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A real name or alias; postal address; signature; home phone number or mobile phone number; bank account number, credit card number, debit card number, or other financial information; physical characteristics or description; email address; account name; Social Security number; driver's license number or state identification card number; passport number; or other similar identifiers. |
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A real name or alias; postal address; signature; home phone number or mobile phone number; bank account number, credit card number, debit card number, or other financial information; physical characteristics or description; email address; account name; Social Security number; driver's license number or state |
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Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
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Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
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Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
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Browsing history, search history, information on a consumer's interaction with a website, virtual assistant interactions, application, or advertisement. |
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Physical location or movements. For example, city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and, with your permission in accordance with your mobile device settings, and precise geolocation information from GPS-based functionality on your mobile devices. |
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Audio, electronic, visual, thermal, olfactory, or similar information. |
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Current or past job history, performance evaluations, disciplinary records, workplace injury records, disability accommodations, and complaint records. |
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Educational records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
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Profile reflecting a person’s preference, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
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Pictures of checks you have submitted for mobile or desktop deposit, gathered via your mobile device with your permission in accordance with your mobile device settings or via high-capacity desktop scanner purchased to use the business desktop deposit product. |
2. INFORMATION THAT YOU PROVIDE TO ROYAL
You may provide personal information directly to Royal both online and offline for different reasons. This information includes, but is not limited to, your name, address, email address, and phone number. You may also provide personal information to Royal online when you complete an online form on the online services, pay a bill online, use the virtual assistant, or subscribe to electronic communications from Royal.
Other ways you may provide personal information are when you provide feedback to Royal through the online services, respond to surveys and questionnaires that Royal sends you, provide information to Royal team members, including our virtual assistant, or provide personal information to Royal through other online means.
You may provide personal information offline to Royal when you complete membership or credit applications (e.g., to open a Royal account or apply for a loan), provide information to Royal team members, deposit money, use your debit card, or provide personal information to Royal through other offline means.
When you sign up for or maintain a financial account with Royal, you may provide the types of personal information described in Royal’s Privacy Policy, including but not limited to your Social Security number and employment information.
3. INFORMATION AUTOMATICALLY COLLECTED BY ROYAL
In addition to the information you provide, when you use the online services, Royal may also automatically collect the following types of information from your devices and applications that you use:
- Royal Websites: If you use Royal’s websites, Royal may collect certain information from your device or web browser, including but not limited to your browser type, your geographic location, the date and time of your visit, and the Royal website pages that you visit (collectively, the “website data”). Royal may collect this information through the use of cookies, Adobe Flash objects, floodlight tags, pixel tags, web beacons, and log files. Website data alone (i.e., when it is not associated with other personal information) is not deemed to be personal information.
- Royal Mobile Applications: If you choose to use a Royal mobile application, Royal may collect certain information from the application and your mobile device (collectively, the “mobile app data”), including but not limited to geographic location information, unique device identifier information, and website data (as defined above). If the Royal mobile application collects any sensitive information from your mobile device that is not identified here, then Royal will notify you before doing so.
- Royal Virtual Assistant: If you choose to use Royal’s virtual assistant, Royal may collect certain information from your device or web browser, including but not limited to your browser type, your browser version, your operating system version, the user agent string, and the date and time of your visit. Royal may collect this information through the use of cookies and request headers.
4. INFORMATION COLLECTED FROM THIRD PARTY SOURCES
In addition to personal information that you provide to Royal, Royal may also collect information about you, including personal information, from third-party sources, including but not limited to credit reports from consumer reporting agencies and information from propensity information sellers (collectively, “third-party data”). This includes, but is not limited to instances in which you affirmatively authorize third parties to provide Royal with information. Third-party data includes both personal information and information that is not personally identifiable to you.
When you sign up for an account with Royal, Royal may also collect information about you, including personal information, from third-party sources as described in Royal’s Privacy Policy, including, but not limited to your credit history, payment history, and account balances.
5. INFORMATION COLLECTED FROM ONLINE TOOLS
Royal may feature certain tools through the online services, such as online calculators (collectively, the “online tools”). The online tools do not require you to log in to online banking or enter your contact information to use the online tool. The information you provide when using the online tools is not associated with you or your account and, for purposes of this Privacy Notice, is not considered to be personal information.
III. USE AND SHARING OF COLLECTED INFORMATION
1. COLLECTED INFORMATION
Royal may use your personal information, third-party data, mobile app data, website data, and forum postings to:
- Provide you with services or other products, financial services, and information that you have requested or in connection with the financial services;
- Maintain your account;
- Allow you to apply for products or services and process your applications and transactions;
- Manage Royal’s business, including performing accounting, auditing, and other internal functions;
- Verify your identity and authenticate you (such as when you request access to your account information);
- Communicate with you about your account, in response to your requests, to notify you about important information regarding financial services, and to provide you with other administrative information;
- Communicate with you about special offers, ads, events, or new products or services that may be of interest to you;
- Evaluate and improve Royal’s websites and other offerings;
- Enhance the learning and understanding of our virtual assistant;
- To assist in the growth and development of the credit union through virtual assistant analytics;
- Provide you with member service;
- Personalize and tailor the financial services and otherwise enhance the member experience;
- Conduct research and perform analysis in order to measure, maintain, protect, develop, and improve Royal’s products and financial services;
- Use in the case of risk control, fraud detection, and prevention;
- Comply with laws and regulations, contractual obligations, and Royal’s internal policies; and
- Use for other purposes as permitted by applicable law.
Royal may share or disclose collected information (including personal information) in the following situations:
- With third parties acting on Royal’s behalf, such as third party payment card processors, call-center operators, virtual assistant providers, shippers, servicers, marketing providers, people who analyze data for Royal, and other service providers;
- With other financial companies for joint marketing purposes (e.g., to bring you co-branded services or products);
- If Royal is involved in any merger, acquisition, sale of assets, transition of service to another provider, or insolvency, bankruptcy, or receivership, Royal reserves the right to transfer your collected information (including personal information) in connection with such transaction;
- If Royal determines a website or policy violation has occurred, or to enforce Royal’s Website Terms of Use;
- If Royal believes such disclosure is necessary to identify, contract, or bring legal action regarding injury or interference with the rights and property of Royal, including to enforce Royal’s rights against unauthorized access or attempted unauthorized access to our information technology assets or against other inappropriate use of the financial services;
- To report to credit bureaus;
- To comply with laws, regulations, court orders, and subpoenas or similar requests for information by authorities, or as otherwise required by law;
- To respond to an emergency;
- To protect the rights, property, safety, and security of Members and others; and
- To assist Royal in preventing or investigating fraud, security, technical issues, or to otherwise manage risks.
In the preceding twelve (12) months, Royal may have disclosed the following categories of personal information for a business purpose:
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Category |
Examples |
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A real name or alias; postal address; signature; home phone number or mobile phone number; bank account number, credit card number, debit card number, or other financial information; physical characteristics or description; email address; account name; Social Security number; driver's license number or state identification card number; passport number; or other similar identifiers. |
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A real name or alias; postal address; signature; home phone number or mobile phone number; bank account number, credit card number, debit card number, or other financial information; physical characteristics or description; email address; account name; Social Security number; driver's license number or state |
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Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). |
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Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
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Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
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Browsing history, search history, information on a consumer's interaction with a website, virtual assistant, application, or advertisement. |
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Physical location or movements. For example, city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and, with your permission in accordance with your mobile device settings, and precise geolocation information from GPS-based functionality on your mobile devices. |
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Audio, electronic, visual, thermal, olfactory, or similar information. |
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Current or past job history, performance evaluations, disciplinary records, workplace injury records, disability accommodations, and complaint records. |
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Educational records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
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Profile reflecting a person’s preference, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
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Pictures of checks you have submitted for mobile or desktop deposit, gathered via your mobile device with your permission in accordance with your mobile device settings or via high-capacity desktop scanner purchased to use the business desktop deposit product. |
If you are a Royal Member, Royal may use and share your personal information as described in Royal’s Privacy Policy, which also provides information about how you may limit certain types of sharing.
Categories of affiliates and nonaffiliated third parties to whom Royal discloses.
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Category |
Examples |
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2. AGGREGATED DATA
Royal may aggregate collected information gathered from Royal’s various users so that it no longer identifies you specifically and share it with Royal’s business partners and other third parties. Royal may also store such aggregated data for a reasonable period of time after you terminate your account(s) or stop using the financial services.
The aggregated data may also be used by Royal or third parties for research purposes, including to help Royal improve its products and financial services. This, among other uses, allows companies to develop better products for Royal’s Members.
3. WEBSITE DATA
In addition to the uses described above, Royal may use website data to improve the financial services, as well as help Royal understand how Members are using the financial services. This information is also collected for statistical analysis, to determine what information is of most and least interest to Royal’s Members, to improve the usefulness of the financial services, and finally, for other purposes described in this Privacy Notice. Royal may share website data with its business partners and other third parties (including for the reasons listed above).
IV. REVIEW AND CORRECTION OF PERSONAL INFORMATION
You may review, correct, and update certain personal information (such as your name and contact information) by signing in to online banking on the Royal website or the Royal mobile application and editing the information listed in your account profile.
You may also correct or update your personal information by contacting us via the Contact Us section below or by making the request in person at any of a Royal branch location.
V. OPTING OUT
You may occasionally receive emails from Royal, including emails about products or financial services, marketing or promotions, research, and/or other topics. To contact you, Royal may use the information you provide, including email, direct (postal) mail, or phone. You may, at any time, inform Royal that you do not want Royal to contact you with marketing or promotional communications by sending your request via the Contact Us section below.
Do you wish to opt out of Royal’s promotional emails? Simply click on the email opt out link. After you opt out of marketing and promotional messages, you’ll still receive other transactional messages, such as notifications and information relating to your account and services. If you also wish to opt out of these transactional email notifications, simply unsubscribe using the opt out link.
Do you want to opt out of receiving emails? Contact Us
VI. SAFEGUARDING YOUR INFORMATION
Royal is committed to maintaining the security of the data you provide. Royal uses security controls that comply with applicable federal laws to protect against unauthorized access and use of your personal information that is in Royal’s custody or control. Safety measures may include computer safeguards, secured files, and buildings. To learn more about Royal’s security practices, visit the Security and Fraud page on the Royal website.
While Royal is focused on the security of your personal information, you must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others. For this reason, Royal cannot promise, and you should not expect, that Royal will be able to protect your personal information at all times and in all circumstances. Royal cannot guarantee the security and privacy of transmissions via the Internet, and Royal will not be liable for any lack of security relating to the use of the financial services by you. You agree that you will not hold Royal liable for any damages resulting from any loss of privacy or security occurring in connection with any such communications.
VII. CALIFORNIA RESIDENTS
Are you a California resident? The California Consumer Privacy Act (“CCPA”) provides consumers (California Residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Your Rights Under the CCPA
- Right to know the information Royal collects about you
- Right to know what information Royal shares about you
- Right to request:
- The categories of personal information collected about you within the preceding twelve (12) months
- The categories of sources from which the personal information is collected
- The business or commercial purpose for collecting personal information
- The categories of third parties with whom information is shared
- The specific pieces of personal information that Royal collected about you
- Right to request deleting of certain personal information
- Right to non-discrimination in accessing products and services when exercising these rights
Right to Know
Under the CCPA, consumers (California residents) have the right to request that Royal disclose certain personal information that it collects, uses, discloses and sells that is not subject to the exemption of information covered under the federal Gramm-Leach-Bliley Act and implementing regulations, California Financial Information Privacy Act, or the Fair Credit Reporting Act. To request this information complete our online form or call us at 800-341-9911.
By law and regulation Royal is required to positively verify your identity prior to responding to your request. Below are ways Royal will attempt to positively verify your identity:
- If you have online banking with Royal, you may submit a secure message request and additional information will not be required to be submitted.
- If you do not have online banking, you will need to provide valid identification including a state-issued driver’s license, ID card or US or other government-issued passport; plus a document proving your address such as the address portion of a utility bill, bank, investment or credit card statement (number redacted) that contains the name and address that matches your ID and information request.
- If making a request by phone, we will require you to send Royal the information above to verify your identity.
- If you are requesting to know specific pieces of information a higher degree of verification may be required. Royal will also require, pursuant to CCPA regulations, that you submit a signed declaration under penalty of perjury that you are the consumer to whom the information relates.
- If Royal is unable to positively identify the person making the request is the consumer to whom the information relates, Royal may ask for additional verification or may deny the request.
If you use an authorized agent to submit a request to know information under CCPA, you must provide the agent a signed written permission which the agent will have to provide us in order to submit the request on your behalf. An agent’s failure to provide proof of authorization will result in a denial of the request.
Right to Request Deletion of Personal Information
Under CCPA, consumers have the right to request that a business delete any personal information about the consumer which the business has collected from the consumer. Consumers can exercise this right by making a verifiable request. The business must delete the consumer’s personal information from its records and direct any service providers to delete the consumer’s personal information from their records. Please note that a business does not have to honor such request if the personal information is necessary to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and consumer.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
- Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
- Comply with a legal obligation.
- Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Non-Discrimination
Royal will not discriminate against a consumer who has exercised any of their rights under the CCPA.
VIII. TRACKING; THIRD-PARTY ANALYTICS PROVIDERS; ADVERTISING
1. DO NOT TRACK DISCLOSURE
Certain web browsers may provide a do-not-track (“DNT”) option. You may be able to ask your browser to inform websites that you do not wish your activities to be tracked, either with cookies or other persistent identifiers, commonly called “DNT signals.” Because there is not yet a common understanding of how to interpret web browser-based DNT signals other than cookies, Royal’s websites do not currently respond to DNT signals.
2. THIRD-PARTY ANALYTICS PROVIDERS
Royal works with third-party analytics providers, including but not limited to Google Analytics and Google Adwords, to better understand how Royal websites are used.
For example, Royal uses Google Analytics to learn about the types of users that visit Royal’s websites and to help improve the Royal websites. Google Analytics provides data regarding the demographics of the users that visit the Royal websites.
To provide this service, Google Analytics may collect certain information about you from your computer, including but not limited to:
- information regarding your visit (such as the pages you visit and the length of your visit)
- information about your device (such as your IP address)
- how you got to the website, and other information about you.
You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: google.com/policies/privacy/partners/.
You can opt-out of Google Analytics by using the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout/.
Other ways you can opt out of other website data tracking include:
- accessing the Royal websites via the private browsing function on your browser
- clearing the cookies on your browser on a regular basis, and
- going to https://adssettings.google.com to set your preferences on Google tracking.
3. ADVERTISING
Third parties may collect certain information on third-party websites where Royal advertises; however, Royal does not allow third parties to collect users’ personal information on Royal’s websites or through the online services.
IX. EXCLUSIONS
The online services may contain links to websites owned by other companies. When you leave Royal’s website or the online services and go to another linked website, Royal is not responsible for the content or availability of the linked website. Please be advised that if you enter into a transaction on the third-party website, Royal does not represent either the third party or you. Further, the privacy and security policies of the linked website may differ from those practiced by Royal. Royal is not responsible for the content or privacy practices of websites owned by other companies. Royal recommends that you carefully review the privacy notice for each of the websites you visit because Royal has no control over the privacy practices or content of these linked sites.
The online services are intended for use within the United States (unless otherwise specified). This includes any information you provide using either the online services.
Accordingly, if you do not reside in the United States and are using the online services, any personal information you provide may be transferred to and processed on computers in the United States and other countries.
The data protection and privacy laws of other countries, including the United States, may not afford you the same level of protection as those in your own country. Do not provide your personal information to Royal if you do not want this information to be transferred outside of your country, or if the laws in your country restrict these types of transfers. Royal handles the personal information you provide in accordance with this Privacy Notice.
By doing business or interacting with Royal, using the financial services, using the online services, or by otherwise providing us with your personal information, you agree to the terms of this Privacy Notice and consent to the transfer, storage, and processing of your personal information to and within facilities located in the United States and other facility locations selected by Royal.
This Privacy Notice addresses Royal’s procedures for handling the personal information of Members in the United States who are at least 13 years old. Royal does not seek to, nor do Royal knowingly collect, information from children under 13 years old.
X. CONTACT US
Do you have questions about this Privacy Notice? Royal loves chatting with Members! Ask Royal questions about this Privacy Notice if there is something you don’t understand.
Do you need to update your information? It’s very important to keep your account and contact information up to date. Some of your account information can be changed online, but you can also request changes in other ways.
To update your information online, go to the Self Service section in Online Banking.
To update or change any of your information in person, visit one of Royal’s neighborhood financial center locations or contact Royal in one of the following ways:
By Postal Mail:
P.O. Box 970
Eau Claire, WI 54702
By Phone:
800-341-9911
rcu.org
Log in to Online Banking and send Royal a Secure Message.
XI. UPDATES TO PRIVACY NOTICE; CONSENT
Each time you use the financial services, you are indicating you acknowledge and consent to the collection, use, and disclosure of your personal information as set forth in this Privacy Notice.
From time to time, Royal may update this Privacy Notice. If Royal does, Royal will note the date that any changes are made and/or when they become effective (which you can find at the top of this page).
If the changes being made are material (that is, Royal makes a major change in the important points of this Privacy Notice), we may notify you of the changes in a more prominent way, such as through an email. Your inaction or continued use of the financial services after the revised Privacy Notice is posted or after any such notices are sent will expressly indicate that you agree to these changes. If you do not accept the terms outlined in this Privacy Notice or the revised Privacy Notice, please do not provide Royal with personal information or use the financial services or use the online services.