Serving your needs and protecting your personal information are priorities for First Atlantic Federal Credit Union (referenced herein as "FAFCU," "we," "us" or "our").

For purposes of this Policy, "online" means utilization of an internet communication protocol to view, display, access, receive, or transmit information. This Policy covers all our online practices, including, but not limited to our FAFCU.com website, our Online Banking service, and our Mobile Banking service.

WHAT DOES FIRST ATLANTIC FEDERAL 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. The information can include:

• Social Security number and income
• Account balances and payment history
• Credit history and credit scores

Pulsate User Data:

• Location – Always in use. Used for geofencing and beacon scanning essential for advertising/marketing campaign delivery.
• UserID – Pulsate creates a random user GUID upon initial app access, which is later used during every connection with Pulsate. 

This GUID is unique for each device/app and changes after every app reinstall. This ID is used for identifying a user and sending campaigns.

• Product Interaction – Pulsate tracks user’s app entry, app exit, and pages viewed within the app.
• Name – Pulsate collects user’s first name for product personalization purposes.

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 reason First Atlantic Federal Credit Union chooses to share; and whether you can limit this sharing.

REASON WE CAN SHARE YOUR PERSONAL INFORMATION

To Limit Our Sharing

• Call 732-380-3600 or 800-342-1184 (out of area) - our menu will prompt you through our choices.
• Visit us online: www.fafcu.com

Please note:
If you are a new member, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer a member, we can continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Questions?
Call 732-380-3600 or 800-342-1184 (out of area) - our menu will prompt you through our choices.
Or email us at: service@fafcu.com

WHO WE ARE

Who is providing this notice? 
First Atlantic Federal Credit Union

WHAT WE DO

How does First Atlantic Federal 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 Atlantic Federal Credit Union collect my personal information?
We collect your personal information, for example, when you: 

• Open an account 
• Make deposits 
• Pay your bills or use your credit or First Atlantic Federal Credit Union debit card 
• Apply for a loan 
• Withdraw from your account 

We also collect your personal information from others, such as credit bureaus 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 non-affiliates to market to you 

State laws and individual companies may give you additional rights to limit sharing.

What happens when I limit sharing for an account I hold jointly with someone else?
Your choices will apply to everyone on your account unless you tell us otherwise.

DEFINITIONS

Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies. First Atlantic Federal Credit Union has no affiliates.

Non-Affiliates
Companies not related by common ownership or control. They can be financial and non-financial companies. Non-affiliates we share with can include insurance companies.

Joint Marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include companies such as insurance, financial, and credit card service providers.

ACCESSIBILITY AND COOKIES

Cookies are pieces of data stored by your Web browser that are useful for expediting page loads or enhancing your online experience when you return to a website.

Although cookies do not reveal our members' identities, we use cookies to help us confirm our members' identities before granting access to our secure online banking system. To take full advantage of the level of security that we offer, your browser must meet certain requirements, such as supporting 128-bit encryption and being set to allow our servers to create a cookie on your system.

We also use Google Analytics Demographics and Interest Reporting cookies to analyze trends, administer the website, track users’ movements around the website, and gather aggregated demographic information. We may also contract with third-party companies who use cookies to measure the performance of a marketing effort on our behalf. We prohibit these companies from using this information for their marketing purposes or from sharing this information with anyone other than FAFCU. To opt out of data from being used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout.

Please contact us if you have any questions, comments, or concerns about the accessibility of any page on our website.

INFORMATION COLLECTED WHEN YOU VIEW OR VISIT OUR WEBSITE

When you are simply viewing our website, we do not collect or retain any personal or identifiable information. However, for security purposes, and to respond to or fulfill your requests, we will collect and retain personal or identifiable information when you submit such to us, transact with us, or provide you with access to your online account information.

We do collect non-identifying information for internal statistical purposes whenever you visit our website. This statistical information is collected to better enrich the online experience of our visitors, to assess what information is most and least important to our visitors, to analyze the effectiveness of our ads, and to determine whether our content and/or its presentment is useful and relevant to visitors of our website.

WHAT HAPPENS WHEN YOU SEND INFORMATION TO US OR TRANSACT WITH US ONLINE

Whenever you submit information to us using methods we make available to you on our website, we protect your information using administrative and technical processes along with strong industry-standard encryption recommended for financial institutions. There is a serious risk that your information could be intercepted if you send information using a method outside of our website, such as sending an email from your home email server or posting a message to us through a social media website. To send us a secure message, you should only use the method provided by us, through our encrypted email service when instructed by us, or the method provided after logging on to our Online or Mobile Banking services.

HOW TO STOP OR UNSUBSCRIBE FROM RECEIVING COMMUNICATIONS FROM US

If your email address or a phone number for receiving text messages is on record with us, we may periodically send you educational or informational communication about products, services, or events that we believe may interest you. A link to unsubscribe from receiving these messages is included in each communication we send. However, we will still communicate with you in connection with servicing your account, fulfilling your request, or any promotion, service, or program in which you have elected to participate.

CHILDREN'S ONLINE PRIVACY PROTECTION ACT (COPPA)

Unless verifiable consent acceptable to us is obtained from a parent or legal guardian, we do not knowingly collect, maintain, or use personal information obtained from our website about children under 13 years of age. We are not responsible for the data collection or use practices of any party to which our website may link. For more information about the Children's Online Privacy Protection Act (COPPA), visit the Federal Trade Commission website, www.ftc.gov.

LINKS TO OTHER WEBSITES OR WHEN OTHER WEBSITES DISPLAY OUR ADVERTISEMENTS

We are not responsible for the content, practices, or policies of any other party or any non-FAFCU website you visit, including any social media sites in which we display information or any website whose link appears within our website, regardless of any affiliation we may share with any other entity. Before providing any personal or identifiable information, you should review the policies of any website you visit. The fact that there is a link between our website and that of another website does not represent an endorsement by us of the content and any product, service, or program contained on any other website. Ads we place on other websites may contain a "tag," which is a code that tells us that our ad was reviewed at the sponsoring website. Tags do not contain personal or identifiable information and are only a marketing tool for measuring the effectiveness of placing our ads on other websites.

The First Atlantic Mobile Banking App (the “App”) – powered by NCR – helps you control your deposit and loan accounts through your mobile device, making it easy to manage your finances on the go.  

The App allows you to: 

• get real-time balances for your accounts 
• manage your money 
• view your transactions and statements 
• make transfers 
• pay your bills and manage billers 
• deposit a check 
• receive alerts 

This Privacy Policy, in combination with other relevant privacy notices that we provide to you (e.g., pursuant to financial privacy laws), inform you of the policies and practices regarding the collection, use and disclosure of any personal information that we and our service providers collect from or about users in connection with the App’s website and mobile application (the “Services”).  

APPLICATION PERMISSIONS

In order to provide certain features of the Application, the Application will request Your prior permission to access Your Device as follows:

THE TYPES OF INFORMATION WE COLLECT IN THE APP 

Through your use of the Services, we may collect personal information from you in the following ways: 

(a) Personal Information You Provide to Us. 

• We may collect personal information from you, such as your first and last name, address, e-mail, telephone number, and social security number when you create an account. 

• We will collect the financial and transaction information necessary to provide you with the Services, including account numbers, payment card expiration date, payment card identification, verification numbers, and transaction and payment history. 

• If you provide feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, to send you a reply. 

• We also collect other types of personal information that you provide voluntarily, such as any information requested by us if you contact us via email regarding support for the Services. 

(b) Personal Information Collected from Third Parties. We may collect certain information from identity verification services and consumer reporting agencies, including credit bureaus, in order to provide some of our Services. 

(c) Personal Information Collected Via Technology. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our communications and other online services, such as: 

• Device data, such as your computer's or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area. 

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access. 

• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns. 

• Local storage technologies, like HTML5 and Flash, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.  

• Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. 

• Location Information. If you have enabled location services on your phone and agree to the collection of your location when prompted by the Services, we will collect location data when you use the Services even when the app is closed or not in use; for example, to provide our fraud detection services.  If you do not want us to collect this information, you may decline the collection of your location when prompted or adjust the location services settings on your device. 

HOW WE USE YOUR INFORMATION COLLECTED IN THE APP 

(a) General Use. In general, we use your personal information collected through your use of the Services to respond to your requests as submitted through the Services, to provide you with the Services you request, and to help serve you better. We use your personal information, in connection with the App, in the following ways: 

• facilitate the creation of, and secure and maintain your account; 

• identify you as a legitimate user in our system; 

• provide improved administration of the Services; 

• provide the Services you request; 

• improve the quality of experience when you interact with the Services; 

• send you administrative e-mail notifications, such as security or support and maintenance advisories; and 

• send surveys, offers, and other promotional materials related to the Services. 

(b) Compliance and protection. We may use your personal information to: 

• comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; 

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);  

• audit our internal processes for compliance with legal and contractual requirements and internal policies;  

• enforce the terms and conditions that govern the Service; and  

• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. 

(c) Creation of Non-Identifiable Data. The App may create de-identified information records from personal information by excluding certain information (such as your name) that makes the information personally identifiable to you. We may use this information in a form that does not personally identify you to analyze request patterns and usage patterns to enhance our products and services. We reserve the right to use and disclose non-identifiable information to third parties at our discretion. 

DISCLOSURE OF YOUR PERSONAL INFORMATION 

We disclose your personal information collected through your use of the Services as described below. 

(a) In Accordance with Our Other Privacy Notices. Other than as described in this Privacy Policy in connection with the App, this Privacy Policy does not apply to the processing of your information by us or third parties with whom we share information. 

(b) Third Party Service Providers. We may share your personal information with third party or affiliated service providers that perform services for or on behalf of us in providing the App, for the purposes described in this Privacy Policy, including: to provide you with the Services; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the Services; to provide technical support; and/or to provide other services to the App.  

 (c) Authorities and Others. Regardless of any choices you make regarding your personal information, The App may disclose your personal information to law enforcement, government authorities, and private parties, for the compliance and protection services described above. 

LINKS TO OTHER SITES 

The App may contain links to third party websites. When you click on a link to any other website or location, you will leave the App and go to another site and another entity may collect personal and/or anonymous information from you. The App’s provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites. We encourage you to read the privacy policy of every website you visit. 

YOUR CHOICES REGARDING YOUR INFORMATION 

You have several choices regarding the use of information on the Services. 

 (a) How We Respond to Do Not Track Signals. Some web browsers transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise its policy on responding to these signals. 

(b) Access, Update, or Correct Your Information.  You can access, update or correct your information by changing preferences in your account. For additional requests, please contact us.   

(c) Opting Out of Email or SMS Communications. If you have signed-up to receive our email marketing communications, you can unsubscribe any time by clicking the "unsubscribe" link included at the bottom of the email or other electronic communication. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information under "Contact Us" below. If you provide your phone number through the Services, we may send you notifications by SMS, such as provide a fraud alert. You may opt out of SMS communications by unlinking your mobile phone number through the Services. 

(d) Opting Out of Location Tracking. If you initially consented to the collection of geo-location information through the Services, you could subsequently stop the collection of this information at any time by changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you may no longer be able to use some features of the App. 

SAFEGUARDS AND RETENTION 

We implement reasonable administrative, technical and physical measures in an effort to safeguard the information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information. 

A NOTE ABOUT CHILDREN 

The Services are not directed towards individuals under the age of 18, and we do not, through the App, intentionally gather personal information about visitors who are under the age of 18. If a child under 18 submits personal information to us through the App and we learn that the personal information is the information of a child under 18, we will attempt to delete the information as soon as possible. 

PRIVACY POLICY UPDATES 

This Privacy Policy is subject to occasional revision. We will notify you of any material changes in the collection, use, or disclosure of your personal information by posting a notice on the Services. Any material changes to this Privacy Policy will be effective thirty (30) calendar days following notice of the changes to the Services. These changes will be effective immediately for new users of the Services. If you object to any such changes, you must notify us prior to the effective date of such changes that you wish to deactivate your account. Continued use of the Services following notice of any such changes shall indicate your acknowledgement of such changes. 

CONTACT US 

If you have any questions or complaints about this Privacy Policy or The App’s data collection or processing practices, or if you want to report any security violations to The App, please contact The App by email at: service@fafcu.com or by mail at: 

First Atlantic Federal Credit Union 
468 Industrial Way West 
Eatontown NJ 07724