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EMBARRASS VERMILLION FEDERAL CREDIT UNION

PRIVACY POLICY 2023

GOVERNING LAW/REGULATION

• Gramm-Leach-Bliley Act of 1999, 15 U.S.C. 6801 et seq.

• Consumer Financial Protection Bureau (CFPB) Privacy of Consumer Financial Information, Regulation P, 12 CFR 1016

PURPOSE

Laws governing the treatment of consumer’s nonpublic personal information serve to protect consumers from unlimited disclosure of personal financial information. Financial institutions may disclose, under certain conditions, nonpublic personal information about consumer members to affiliates and nonaffiliated third parties, provided appropriate notice has been provided to each consumer who obtains a credit union product or service, and the consumer has not opted out of such a disclosure.

POLICY STATEMENT

Embarrass Vermillion Federal Credit Union (EVFCU) recognizes its responsibility to protect the privacy of member nonpublic personal information. EVFCU is committed to providing financial products and services that will enable our members to meet their financial needs and goals while at the same time protecting the members’ personal information.

It is the intent of EVFCU to comply with applicable laws and regulations governing the privacy of nonpublic personal information.

DEFINITIONS

For this policy, the following definitions shall apply.

• Affiliate means any company that controls, is controlled by, or is under common control with another company. They can be financial or n nonfinancial companies.

• Non-Affiliate means any company not related by common ownership or control. They can be financial and non-financial companies.

• Consumer means an individual who obtains or has obtained a financial product or service from you that is to be used primarily for personal, family, or household purposes, or that individual’s legal representative.

• Nonpublic personal information means personally identifiable financial information; and any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available.

• Personally identifiable financial information means any information a consumer provides to you to obtain financial products or service from you as the result of any transaction.

GUIDELINES

To ensure that members can rely on the quality of products and services we make available, EVFCU stands behind the following privacy guidelines.

• EVFCU will only collect personal information necessary to conduct our business. That means only what is necessary to provide competitive financial products and services and no more. We collect this information about members from applications and other forms, information about member transactions with us, our affiliates or others, and information we receive from consumer reporting agencies.

• EVFCU discloses nonpublic personal information about its members and former members to companies that offer financial services provided to the membership. The credit union also discloses nonpublic information to other non-affiliated third parties as permitted by law.

• EVFCU will partner only with businesses that follow strict confidentiality requirements. The businesses we select will offer products designed to enhance our members’ economic well-being. Under no circumstances will we authorize those firms to charge a member’s account without receiving their express consent, and we will not sell member information to marketing firms.

• Members that prefer that we not disclose nonpublic personal information about them to nonaffiliated third parties may opt out of these disclosures, and direct us not to make those disclosures to nonaffiliated third parties. To opt out, members may call us at (218) 229-2048. Members may also notify us in writing by mailing a request to PO Box 220, Aurora, MN 55705.

• The right to opt out does not apply if EVFCU’s disclosure of nonpublic personal information is necessary to effect, administer or endorse a transaction that a consumer requests or authorizes.

CONFIDENTIALITY AND SECURITY SAFEGUARDS

EVFCU will protect the personal information of its members. The credit union will maintain strong security controls to ensure that member information in our files and computers I protected. We limit employee access to confidential member financial information to those employees with a business reason for knowing such information. Additionally, we maintain physical, electronic, and procedural safeguards that comply with federal regulations.

DISCLOSURE OF PRIVACY POLICY

EVFCU will disclose its privacy policies as required by law.

An initial privacy notice will be provided to consumer members at the time a member relationship is established. If there is a change in the model privacy form or the credit union changes its privacy practices, revised privacy notice will be provided to members in a conspicuous form they may keep.

A privacy notice will be provided to all members annually with a periodic statement or electronic delivery, based on statement delivery preferences.

TRAINING

Training will emphasize the confidentiality and integrity of nonpublic personal information, and duties of employees to protect such information. Training will emphasize the confidentiality and integrity of nonpublic personal information, and duties of employees to protect such information.

BOARD REVIEWED: 5/2021, 5/2022, 5/2023