Privacy Policy

At Harvard FCU, we are committed to protecting your privacy and ensuring you have a positive experience on our website and with our services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information.

Last Updated: January 2025

1. Introduction

Harvard Federal Credit Union ("we," "us," "our," or "Company") operates the Harvard FCU website and provides financial services to our members. We are committed to maintaining the trust and confidence of our members and protecting their personal information.

This Privacy Policy applies to our website, mobile applications, and all services provided by Harvard FCU. By accessing our website or using our services, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms. If you do not agree with our privacy practices, please do not use our website or services.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by updating the "Last Updated" date at the top of this policy. Your continued use of our website and services following the posting of revised Privacy Policy means that you accept and agree to the changes.

2. Information We Collect

We collect information about you in various ways, including information you provide directly to us and information collected automatically when you interact with our website and services.

2.1 Information You Provide Directly

We collect information that you voluntarily provide to us, including:

  • Account Information: When you open an account or apply for services, we collect your name, address, phone number, email address, date of birth, Social Security number, employment information, and financial information.
  • Transaction Information: We maintain records of your transactions, including deposits, withdrawals, transfers, and loan payments.
  • Communication Information: When you contact us via phone, email, or in person, we collect information about your inquiries and our responses.
  • Application Information: When you apply for loans or other products, we collect relevant financial and personal information necessary to process your application.
  • Feedback and Surveys: We may collect feedback, survey responses, and other information you voluntarily provide about your experience with our services.

2.2 Information Collected Automatically

When you visit our website or use our services, we automatically collect certain information, including:

  • Device Information: We collect information about the devices you use to access our services, including device type, operating system, unique device identifiers, and mobile network information.
  • Usage Information: We track your interactions with our website and applications, including pages visited, links clicked, features used, and the duration of your visits.
  • Location Information: We may collect approximate location information based on your IP address or, with your permission, precise location information from your mobile device.
  • Log Data: Our servers automatically record information created by your use of our website, including IP addresses, browser type, referring pages, and access times.
  • Cookies and Similar Technologies: We use cookies, web beacons, pixels, and similar tracking technologies to enhance your experience and gather information about how our website is used.

2.3 Information from Third Parties

We may receive information about you from third parties, including:

  • Credit reporting agencies and consumer reporting agencies
  • Other financial institutions and service providers
  • Government agencies and law enforcement
  • Employers and employment verification services
  • Marketing partners and data providers
  • Social media platforms (if you connect your account to our services)

3. How We Use Your Information

We use the information we collect for various purposes, including:

3.1 Providing Services

  • Opening and maintaining your account
  • Processing transactions and loan applications
  • Providing customer service and support
  • Sending account statements and notices
  • Responding to your inquiries and requests
  • Delivering the products and services you have requested

3.2 Compliance and Legal Obligations

  • Complying with applicable laws, regulations, and legal processes
  • Verifying your identity and preventing fraud
  • Maintaining records as required by financial regulations
  • Responding to government requests and investigations
  • Establishing, exercising, or defending legal claims

3.3 Marketing and Communications

  • Sending promotional materials and marketing communications (with your consent where required)
  • Notifying you about changes to our services
  • Conducting surveys and gathering feedback
  • Personalizing your experience on our website
  • Informing you about new products and services

3.4 Analytics and Improvement

  • Analyzing usage patterns and trends
  • Improving our website, applications, and services
  • Conducting research and developing new products
  • Monitoring website performance and security
  • Enhancing user experience and functionality

3.5 Risk Management and Fraud Prevention

  • Detecting and preventing fraudulent transactions
  • Assessing credit risk and managing accounts
  • Monitoring for suspicious activity
  • Protecting against unauthorized access

We will not use your information for purposes other than those described in this Privacy Policy without obtaining your consent, except as required by law.

4. Sharing Your Information

We may share your information with third parties in the following circumstances:

4.1 Service Providers

We share information with third-party service providers who assist us in operating our website, conducting our business, and providing services to you. These providers include technology vendors, payment processors, data analytics companies, and customer service providers. We require these service providers to maintain the confidentiality of your information and use it only for the purposes we specify.

4.2 Affiliate Organizations

We may share information with our affiliate organizations to provide you with products and services, improve our offerings, and conduct joint marketing initiatives. We ensure that our affiliates maintain appropriate safeguards for your information.

4.3 Legal Requirements

We may disclose your information when required by law or when we believe in good faith that such disclosure is necessary to comply with legal obligations, enforce our agreements, or protect the rights, privacy, safety, or property of Harvard FCU, our members, or the public.

4.4 Business Transfers

If Harvard FCU is involved in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a different privacy policy.

4.5 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing. You may withdraw your consent at any time by contacting us.

4.6 Aggregate and De-identified Information

We may share aggregate, anonymized, or de-identified information that cannot reasonably be used to identify you with third parties for marketing, analytics, and research purposes.

Important: We do not sell, rent, or lease your personal information to third parties for their marketing purposes. We share your information only as described in this Privacy Policy or as required by law.

5. Cookies and Similar Technologies

5.1 What Are Cookies?

Cookies are small text files that are stored on your device when you visit our website. They contain information about your browsing activity and preferences. Cookies help us recognize you, remember your preferences, and enhance your experience on our website.

5.2 Types of Cookies We Use

  • Essential Cookies: These cookies are necessary for the website to function properly and cannot be disabled. They enable core functionality such as security, authentication, and account access.
  • Performance Cookies: These cookies collect information about how you use our website, including which pages you visit and how long you stay on each page. This helps us improve website performance and user experience.
  • Functional Cookies: These cookies remember your preferences and choices, such as language settings and account preferences, to personalize your experience.
  • Marketing Cookies: These cookies track your activity across websites to deliver targeted advertising and marketing content tailored to your interests.

5.3 Other Tracking Technologies

In addition to cookies, we may use other tracking technologies, including:

  • Web Beacons: Small, transparent images embedded in web pages that track whether a page has been visited.
  • Pixels: Small code snippets that track user interactions and conversions.
  • Local Storage: Technology that stores information on your device similar to cookies.
  • Analytics Tools: Third-party analytics services that track and analyze user behavior on our website.

5.4 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent. Please note that disabling cookies may affect the functionality of our website and your ability to access certain features. To manage cookies, you can:

  • Adjust your browser settings to refuse cookies
  • Delete cookies from your device
  • Use private or incognito browsing modes
  • Opt out of third-party tracking services

5.5 Do Not Track Signals

Some browsers include a "Do Not Track" feature. Currently, there is no industry standard for recognizing Do Not Track signals, and Harvard FCU does not respond to Do Not Track browser signals. However, you can use the cookie management tools described above to control tracking on our website.

6. Data Security

We implement comprehensive security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of sensitive data in transit and at rest using industry-standard SSL/TLS protocols
  • Secure authentication mechanisms including multi-factor authentication
  • Regular security audits and vulnerability assessments
  • Firewalls and intrusion detection systems
  • Access controls limiting employee access to personal information
  • Employee training on data protection and privacy practices
  • Incident response procedures for data breaches
  • Compliance with NCUA and other regulatory security requirements

While we employ robust security measures, no method of transmission over the internet is completely secure. We cannot guarantee absolute security of your information. You are responsible for maintaining the confidentiality of your login credentials and account information. If you believe your account has been compromised, please contact us immediately.

7. Your Privacy Rights

7.1 Access and Correction

You have the right to access the personal information we maintain about you and to request corrections to inaccurate or incomplete information. You can access your account information through our online banking portal or by contacting us directly.

7.2 Data Portability

You have the right to request a copy of your personal information in a portable format. We will provide your information in a structured, commonly used, and machine-readable format upon request.

7.3 Deletion Requests

You may request deletion of your personal information, subject to legal and regulatory requirements. We may retain certain information as required by law, regulation, or for legitimate business purposes. Please note that deletion of information may affect your ability to use certain services.

7.4 Marketing Communications

You can opt out of receiving marketing communications from us at any time by clicking the unsubscribe link in our emails, adjusting your account preferences, or contacting us directly. Please note that even if you opt out of marketing communications, we will continue to send you transactional messages related to your account.

7.5 California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know, delete, and opt-out of the sale of your personal information. To exercise these rights, please contact us using the information provided in the Contact Us section below.

7.6 Exercising Your Rights

To exercise any of your privacy rights, please contact us at the address, phone number, or email provided in Section 8 below. We will respond to your request within the timeframe required by applicable law, typically within 30 days.

8. Third-Party Links and Services

Our website may contain links to third-party websites, applications, and services that are not operated by Harvard FCU. This Privacy Policy applies only to our website and services. We are not responsible for the privacy practices of third-party websites or services, and we encourage you to review their privacy policies before providing your information.

When you click on a third-party link, you are leaving our website and entering a different website. We have no control over and assume no responsibility for the content, accuracy, or practices of third-party websites.

9. Children's Privacy

Our website and services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information and terminate the child's account.

For children between 13 and 18, we provide additional privacy protections and encourage parents and guardians to be involved in their children's online activities.

If you believe we have collected information from a child under 13, please contact us immediately using the information provided in Section 10 below.

10. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Harvard Federal Credit Union

Privacy Officer

If you wish to speak with our Privacy Officer regarding data protection matters or to file a privacy complaint, please contact us at the email address above and reference "Privacy Officer" in your subject line.

Regulatory Authorities

If you are not satisfied with our response to your privacy concerns, you may have the right to lodge a complaint with your local data protection authority or regulatory agency.

11. International Users

If you are accessing our website or services from outside the United States, please be aware that your information will be transferred to, stored in, and processed in the United States. The United States may not have the same data protection laws as your home country. By using our website and services, you consent to the transfer of your information to the United States and the processing of your information in accordance with this Privacy Policy.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by updating the "Last Updated" date at the top of this policy and, where appropriate, by providing additional notice (such as by email or prominently on our website).

Your continued use of our website and services following the posting of a revised Privacy Policy means that you accept and agree to the changes. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.