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CAROLINA FEDERAL CREDIT UNION

PRIVACY POLICY



A. Privacy of Consumer Financial Information

1. Carolina Federal Credit Union (CFCU) shall protect the confidentiality, security and integrity of each member’s nonpublic personal information consistent with the state and federal laws.
2. CFCU shall take careful and reasonable measures to protect the accuracy and privacy of all member information used in conducting business.
3. CFCU will not collect or maintain information about its members that is not essential for prudent business purposes.

B. Responsibilities

1. CFCU officers, directors, committee members and employees are required to hold in confidence all Credit Union transactions with members and all information in regards to members’ personal business.
2. It is the responsibility of all officers, directors, committee members and employees to protect confidential member information.
3. It is the responsibility of all officers, directors, committee members and employees to identify any potential area of exposure and to take steps to report such discovery and to assist in correcting the condition that could permit any potential security breach.
4. It is, further, the responsibility of all officers, directors, committee members and employees to report any actual or threatened release of confidential information and to take steps as may be immediately available to prevent or to halt such release.

C. Sharing Information

1. It is the policy to prohibit disclosure of member information to third parties (excluding Credit Union affiliates) concerning accounts with us, except:

(a) When such disclosure is necessary to complete transactions.
(b) To verify the existence and condition of an account for a third party (such as a credit bureau) as is permitted by law.
(c) To comply with any court order or applicable laws or regulations.
(d) When given written permission by the member. Federal law protects the information CFCU provides to credit reporting agencies and its use is strictly governed by the Fair Credit Reporting Act.

2. CFCU does not and will not sell or provide personal information to third parties for independent use. We may share personal information with our Credit Union affiliates, for example Members Financial Services, Inc., as allowed by federal law, if that information is required to provide a product or service that we believe members might want to know about.
3. If requested, members may be excluded from receiving marketing materials and solicitations from CFCU’s affiliated third party vendors.


D. Internet Privacy Protection

1. CFCU uses multiple levels of security, beginning with the member’s browser and ending with the Credit Union’s operating system that acts as a virtual information vault inside the Credit Union. Information received via online applications is secured within the mail server and passwords are required for access.
2. CFCU’s website host uses firewalls that are designed to protect account information from unauthorized access outside the Credit Union.

E. Administration and Amendments

1. Protecting member privacy is an ongoing process and CFCU will continue to review the measures taken to safeguard member information.
2. If member information is shared with vendors, all contracts and agreements between the vendor and CFCU will include a guarantee that the vendor will safeguard such information.
3. Since no policy can address every possible contingency and circumstance, CFCU management shall use its good faith business judgment in administering this privacy policy, and expects that all employees and committee members will use good faith in their actions to protect the privacy of credit union members.
4. CFCU reserves the right to amend this policy in any respect.
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