Privacy Notice

Privacy Notice

What Does ASECU Do With Your Personal Information?

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.

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 income
• Account balances and payment history
• Credit history and credit scores

When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share consumers personal information to run their everyday business. In the section below, we list the reasons financial companies can share their consumers personal information; the reasons ASECU chooses to share, and whether you can limit this sharing.

Reasons we can share your personal information

For our everyday business purposes --- such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
For our marketing purposes --- to offer our products and services to you
For joint marketing with other financial companies
For our affiliates’ everyday business purposes --- information about your transactions and experiences
For our affiliates’ everyday business purposes --- information about your creditworthiness
For our affiliates* to market to you
For non-affiliates** to market to you

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 ASECU collect my personal information?

We collect your personal information, for example, when you:

• open an account or deposit money
• pay your bills or apply for a loan
• use your credit or debit card
• We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
• sharing for affiliates’ everyday business purposes -- information about your credit worthiness
• 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.

*Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include financial companies such as our wholly owned affiliate, Greater Warren Financial Center, llc.
**Non-affiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies. ASECU does not share with non-affiliates so they can market to you. A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include insurance companies and credit card companies.

If you have questions or concerns about the integrity of your account information please contact us.

ASECU Policy Regarding Account Investigations and Dispute/Error Resolution

In the event of questions, errors, reports of fraud or criminal activity, or requests for information concerning the
same, you must notify the credit union in writing immediately. Your letter of notification must contain the following:

• Name, as it appears on the account,
• Current address and phone number,
• Account number,
• The dollar amount(s) in question,
• The date the transaction(s) in question occurred,
• A detailed description of the problem. If applicable, an explanation as to why the you believe there is an error or fraud.
• If you are requesting more information, please describe the item you are unsure about and outline clearly what information you are requesting, and
• Signature of account owner.

We must hear from you, in writing, NO LATER THAN 60 days after we sent the first statement on which the item in
question appeared. You may telephone us at (330) 792-4000, but doing so will NOT preserve your rights. Your
letter may be delivered during regular business hours, or mailed to the credit union main office located at:

Associated School Employees Credit Union
1690 South Canfield Niles Rd
Austintown, Ohio 44515

If it is suspected that a crime or fraud has taken place, then we will require you to file a report with the police
department or proper authority located within the jurisdiction in which the incident occurred. This report is mandatory
and a copy must be supplied to the credit union immediately upon availability. For your protection, we may
temporarily suspend credit union accounts and access, including (but not limited to) savings, checking, debit cards,
ATM cards, online account access and loans. Furthermore, we may restrict your transactions and communication
to personal visits with valid identification.

We reserve the right to ask for any applicable information or documentation needed for our investigation. In most
cases, we will disclose the results of our investigation within 10 business days after we receive the properly completed
written correspondence. If the authorities are investigating the matter in question, we will allow a reasonable time
for them to conclude their inquiries. If more time is needed, we may take up to 45 days to investigate the claim or
question.

We will disclose our findings within 3 business days after we finish our investigation. If we conclude that there was
no error or fraud, a loss occurred as a result of your or another financial institution’s negligence, or the results of
the investigation are inconclusive, you will be required to pay, in full, any disputed amounts due at that time. You
may also be subject to payment of expenses incurred in the course of the investigation, including, but not limited to,
statement copy fees, research time, and legal expenses. If it is determined that the credit union had committed an
error, we will promptly return any monies due, plus any applicable fees.

You have the right to appeal the findings of the investigation to the credit union Board of Directors within 10
calendar days of receiving notification of the conclusion of our investigation. To initiate the appeal, you must
submit, in writing, a request to have the matter reviewed by the Board of Directors at a regularly scheduled board
meeting. The appeal must explain why you dispute the results of the investigation and provide all supporting
documentation. They should also include copies of the original letter of notification and all relevant documentation.

Upon review of the requested appeal, the Chairman of the Board or his/her designate will notify you of the Board’s
decision by mail within 10 calendar days. All decisions of the credit union Board of Directors is final.

IMPORTANT INFORMATION REGARDING INTERNET GAMBLING AND YOUR ACCOUNT

The Federal Reserve Regulation GG implements the Unlawful Internet Gambling Enforcement Act (UIGEA) to prevent unlawful internet gambling businesses from utilizing the banking system. The Act specifically prohibits businesses from knowingly accepting payment in connection with unlawful internet gambling, including payments made through debit or credit cards, electronic fund transfers and checks. It is the policy of Associated School Employees Credit Union to implement reasonable policies and procedures designed to prevent or prohibit restricted transactions as required by the regulation.

As defined by the regulation, unlawful internet gambling means to “place, receive or otherwise knowingly transmit a bet or wager by any means which involves the use, at least in part, of the internet where such bet or wager is unlawful under any applicable Federal or State law in the State or Tribal lands in which the bet or wager is initiated, received or otherwise made.” 

ASECU is not required to monitor or determine whether a credit union member is a gambler except that it must ensure that unlawful credit and debit card transactions are blocked. However, if you do engage in internet gambling, the credit union reserves the right to block any suspected unlawful transactions. Card networks also have the responsibility to establish policies and procedures to identify and block unlawful transactions. The credit union will rely on our card providers to block the appropriate transactions on credit union Visa Check (debit) Cards and Mastercard credit cards. Both lawmakers and card providers recognize the difficulty in
identifying unlawful versus lawful internet gambling transactions. This means that occasionally legitimate gambling transactions, whether internet or non-internet related, may be denied as a result of compliance with this regulation.

The credit union will also perform UIGEA due diligence upon the opening of an account used for the purpose of business or commerce. Prior to opening a non-consumer account, you may be asked a series of questions related to the use or purpose of your account. If it is determined that the account will be used in conjunction with any facet of gambling, betting or wagering, including incoming or outgoing payments, the account applicant will be asked to provide appropriate documentation to determine the legal authority to engage in the business. Regardless, the credit union may, at its sole discretion, refuse to open an account used for the purpose of
gambling or gambling related processes. We remind our members that using your ASECU account to process or engage in any illegal acts, including unlawful internet gambling is strictly prohibited. Violations may result in the termination of your credit union services or account relationship.

Some additional resources:
The complete text of Regulation GG (12 CFR Part 233) can be found online at:
http://ecfr.gpoaccess.gov, under Title 12, Part 233. The complete text of the UIGEA (31 CFR Part 132) can be found online at: http://ecfr.gpoaccess.gov, under Title 31, Part 132.

ASSOCIATED SCHOOL EMPLOYEES CREDIT UNION ONLINE PRIVACY POLICY - Updated April 1, 2017

Associated School Employees Credit Union (“ASECU”) understands the importance of protecting your privacy.  Our goal is to maintain your trust and confidence when handling your personal information. We are committed to maintaining the confidentiality of your personal information consistent with state and federal laws. This Online Privacy Policy (“Policy”) describes how ASECU collects, uses, shares, and protects information when you visit or use www.asecu.com (“the Website”). By using the Website, you consent to the terms and conditions of this Policy, including your consent to our use and disclosure of information about you in the manner described in this Policy. The term “us,” “we” or “our” in this Policy refers to Associated School Employees Credit Union.

Collecting, Using and Sharing Information 
You may interact with us in a variety of ways online, including through a mobile device. We offer sites and applications that permit browsing and do not require registration. We also offer the ability to access your accounts
online or through a mobile device, which requires you to register and securely login. We may obtain personal information through these various interactions with you.

How We Collect Information
“Cookies” are pieces of information that are stored directly on your computer, smartphone or other internet access device. Browser cookies are assigned by a web server to the browser on your device.  When you return to a website you have visited before, your browser gives this data back to the server.  Cookies we use do not contain or capture unencrypted personal information.  The browsers of most computers, smartphones and other internet access devices are set up to accept cookies. You can refuse to accept these cookies through your browser settings. You will need to manage your cookie settings for each device and browser you use. If you choose to reject cookies, you may not be able to use the full functionality of the Website.

Personal Information We Collect
When you interact with us via our Website, we will not obtain personal information about you unless you choose to provide such information. Personal information that we may collect about you through online interaction
includes information that you provide, such as your name, mailing address, email address and other contact information; data resulting from your activity, such as transaction information; and limited location information
(for example, a zip code to help you find a nearby ATM). We may also collect social security numbers and driver’s license numbers when you provide such information while using our Website.  We will retain your personal
information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Other Information We May Collect
In addition to the personal information described above, we may also collect anonymous demographic information, which is not unique to you, such as your ZIP code, region, preferences, interests, and favorites. We
may also automatically collect information about your computer hardware, such as the IP address of the device you use to connect to the Website, the type of operating system and browser you use, search engine used, access times, referring website addresses, the parts of our Website you access and how often, and the site you visit next.

How We Use Information In addition to the uses described above, we may use the information for purposes as allowed by law, such as:

• To process applications and transactions;
• To service your accounts with us;
• To take collection action or repossess personal property collateral if you are in default on your loan obligations to us;
• To send you important information regarding the Website, changes to terms, conditions and/or policies;
• To track Website usage, such as number of hits, pages visited, and the length of user sessions in order to evaluate the usefulness of our Website;
• To verify your identity (such as when you access your account information);
• To respond to your requests and to communicate with you;
• To send you marketing communications that we believe may be of interest to you;
• To allow you to participate in surveys, sweepstakes, contests and similar promotions;
• For our business purposes, including data analysis, developing and improving our products and services, and enhancing our Website; and
• To prevent fraud and enhance the security of our Website.

How We Share Your Information With Third Parties
If you are an ASECU member, we will use and share any information that we collect from or about you in accordance with our Privacy Policy, which can be viewed on our website.  ASECU may share the information we
collect from and about you with service providers with whom we work, such as our data processors and companies that help us market products and services to you.  When permitted or required by law, we may share information with additional third parties for purposes including response to legal process.

Online Information Privacy for Children
We do not knowingly collect, maintain, or use personal information from our Website about children under the age of thirteen. For more information about the Children’s Online Privacy Protection Act (COPPA), visit the Federal Trade Commission website: www.ftc.gov.

Security
To protect your personal information from unauthorized access and use, we use security measures that comply with applicable federal and state laws. These measures encompass computer safeguards that may include Secure Socket Layer (SSL) technology.  We also limit access to your personal information to those who need it to do their jobs.

Linking to Other Websites
The ASECU website may contain links to third party websites.  Although these links are established to provide you with access to useful information, ASECU does not control and is not responsible for any of these websites or their content. We do not know or control what information third?party websites may collect regarding your personal information. ASECU provides these links to you only as a convenience, and ASECU does not endorse the information, content, presentation or accuracy nor makes any warranty, express or implied, regarding any external site. We encourage you to review the privacy statements of websites you choose to link to from the ASECU Website so that you can understand how those websites collect, use, and share your information. ASECU is not responsible for the security or privacy practices of the linked websites.

Email
If you send us email, we may retain it.  Keep in mind that any unencrypted email sent over the Internet can be intercepted; therefore you should limit the personal information, such as your account number, PIN, Login IDs or passwords, you send us by email.  From time to time, ASECU will send emails to our members to provide information, give notice, make a solicitation or make an inquiry.  We will never ask you to provide account or
personal information by email.  If you receive a request for that type of information, do not respond, and contact ASECU immediately by phone at 330?792?4000.

Social Media
You may also find additional information on our products and services through our social media sites such as Facebook or Twitter.  Please keep in mind that any information you share is visible to all participants on these
social media sites and you should never post any sensitive personal information (such as an account number or taxpayer identification number).  Please refer to the Terms of Use and Privacy Policy on these social media sites as they may be different from ASECU’s policies.
     
Online Planning Tools and Financial Calculators
We provide online planning tools such as information and calculators to help you make financial decisions.  We do not store information that you enter into these planning tools or calculators.  We cannot guarantee their accuracy or their applicability to your circumstances. 
 
Updates to this Online Privacy Policy
We may change this Policy, from time to time, without prior notice to you. The effective date of this policy, as indicated above, reflects the last time this Policy was revised. Any changes to this Policy will become effective
when we post the revised Policy on our Website. Your use of the Website following these changes means that you accept the revised policy.

Collected Information:
We may collect information regarding your mobile device such as device settings, unique device identifiers, information about your location, and analytical information that may assist with diagnostics and performance. For your convenience, you may be asked to grant permission for access to your mobile device's geolocation data. This information may be collected when you use certain services that are dependent on your mobile device’s location (such as the location of an ATM or in store transactions).