Privacy

OUR COMMITMENT TO YOUR PRIVACY & SECURITY

Protecting the privacy and the security of our members’ personal and financial information is Total Community Credit Union’s number one priority when delivering services to our membership, and storing member information.

 Please read our privacy statement:

What does Total Community Credit Union do with your personal information?

Why: Financial institutions 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. This information can include: 

• Name and address 

• Social Security number and income 

• Account balances and payment history 

• Credit history and credit scores

All financial institutions need to share members’ personal information to run their everyday business.  In the section below: we list the reasons financial institutions can share their members’ personal information, the reasons Total Community Credit Union chooses to share, and whether you can limit this sharing. 

Reasons we can share your personal information:

1) 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.
Does Total Community Credit Union share?  Yes
Can you limit this sharing? No

2) For our marketing purposes ‐ to offer our products and services to you.
Does Total Community Credit Union share?  Yes
Can you limit this sharing? No

3) For joint marketing with other financial companies.
Does Total Community Credit Union share?  Yes
Can you limit this sharing? No

4) For our affiliates’ everyday business purposes ‐  information about your transactions,  experiences and creditworthiness.
Does Total Community Credit Union share?  Yes
Can you limit this sharing? No

5) For our affiliates to market to you.
Does Total Community Credit Union share?  Yes
Can you limit this sharing? Yes

6) For nonaffiliates to market to you.
Does Total Community Credit Union share?  Yes
Can you limit this sharing? Yes

To limit our sharing:

• Call 800‐291‐3003, or 

• E‐mail us via our website at www.tccu.us, or 

• Mail your preferences to: Total Community CU. 25155 Goddard Rd., Taylor MI 48180. 

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 our member, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Questions? Call 313-291-3300 or (800) 291-3003 or go to www.tccu.us

This notice is being provided by Total Community Credit Union. TCCU is owned by its members and run by a Board of Directors you elect.

How does Total Community Credit Union protect my personal information?
We restrict access to nonpublic personal information about you to those employees who have a specific business purpose in utilizing your data.  Our employees are trained in the importance of maintaining confidentiality and member privacy.  We maintain physical, electronic, and procedural safeguards that comply with federal regulations and leading industry practices to safeguard your nonpublic personal information.

How does Total Community Credit Union collect my personal information?
We collect your personal information, for example, when you: (1) Open an account or deposit money. (2) Pay your bills or apply for a loan. (3) Use your credit or debit card. (4) We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?
Federal law gives you the right to limit only: (1) Sharing for affiliates’ everyday business purposes ‐ information about your creditworthiness. (2) Affiliates from using your information to market to you. (3) Sharing for nonaffiliates 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 the account.

BIOMETRIC INFORMATION PRIVACY POLICY AND CONSENT– Effective Date: 1/30/2024

Scope and Overview
This policy outlines how Total Community Credit Union, its vendors, and/or the licensor of the Total Community Credit Union’s consumer verification software processes biometric data collected from you for identity verification and fraud prevention purposes.

Biometric Data Defined
As used in this policy, biometric data includes “biometric identifiers” and “biometric information”. “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. As the term is used in this policy, the selfie photograph you upload to the software for use in the biometric algorithm is considered a “biometric identifier.” “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual.

Disclosure and Authorization Policy
To the extent that Total Community Credit Union, its vendors, and/or the licensor of the Total Community Credit Union’s consumer verification software collect, capture, or otherwise obtain biometric data relating to a consumer, Total Community Credit Union must first:

• Inform each consumer that Total Community Credit Union, its vendors, and/or the licensor of the Total Community Credit Union’s consumer verification software are collecting, capturing, or otherwise obtaining the employee’s biometric data, and that the Total Community Credit Union is providing such biometric data to its vendors and the licensor of the Total Community Credit Union’s consumer verification software;

• Inform the consumer of the specific purpose and length of time for which the consumer’s biometric data is being collected, stored, and used; and

• Receive consent by the consumer authorizing Total Community Credit Union, its vendors, and/or Total Community Credit Union’s consumer verification software to collect, store, and use the consumer’s biometric data for the specific purposes disclosed by the Total Community Credit Union, and for Total Community Credit Union to provide such biometric data to its vendors and the licensor of the Total Community Credit Union’s consumer verification software.

• Total Community Credit Union, its vendors, and/or the licensor of the Total Community Credit Union’s consumer verification software will not sell, lease, trade, or otherwise profit from employees’ biometric data; provided, however, that the Total Community Credit Union’s vendors and the licensor of the Total Community Credit Union’s consumer verification software may be paid for products or services used by Total Community Credit Union that utilize such biometric data.

This policy is intended to comply with all federal, state, and local laws.

Purpose for the Collection of Biometric Data
Total Community Credit Union, its vendors, and/or the licensor of Total Community Credit Union’s consumer verification software collect, store, and use biometric data solely for identity verification and fraud prevention purposes.

Disclosure
Total Community Credit Union will not disclose or disseminate any biometric data to anyone other than its vendors and the licensor of the Total Community Credit Union’s consumer verification software providing products and services using biometric data without/unless:

• First obtaining consumer consent to such disclosure or dissemination;

• The disclosed data completes a financial transaction requested or authorized by the consumer;

• Disclosure is required by law or ordinance; or

• Disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Security
Total Community Credit Union shall use a commercially reasonable standard of care to store, transmit and protect from disclosure any biometric data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which Total Community Credit Union stores, transmits and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual or an individual’s account or property, such as genetic markers, genetic testing information, account numbers, PINs, driver’s license numbers and social security numbers.

Retention
Total Community Credit Union shall retain consumer biometric data only until, and shall request that its vendors and the licensor of Total Community Credit Union’s consumer verification software permanently destroy such data when, the first of the following occurs:
• The initial purpose for collecting or obtaining such biometric data has been satisfied, such as verification of consumer identity;
• Request of consumer to destroy the biometric data; or
• Within 30 days of consumer’s provisioning of biometric data.

Contact Information
If you have any questions about our use, storage, or security of your biometric data you can contact us at: creditunion@tccu.us.

BIOMETRIC INFORMATION CONSUMER CONSENT
As outlined in the “Biometric Information Privacy Policy”, I understand and consent to the collection, use, retention, storage, and/or disclosure or re-disclosure of data or images from biometric verification technology by Total Community Credit Union, its vendors, and/or the licensor of the Total Community Credit Union’s consumer verification software. I acknowledge that I have been given a copy of the Policy, or that the Policy has been made accessible to me, and I have had an opportunity to review it and request any additional information concerning the Total Community Credit Union’s procedures and safeguards for collecting, maintaining, using, disclosing, sharing, storing, and/or destroying this data.

Definitions:
Affiliates– Companies related by common ownership or control.  They can be financial and nonfinancial companies.
Nonaffiliate– Companies not related by common ownership or control.  They can be financial and nonfinancial companies.
Joint Marketing– A formal agreement between nonaffiliated financial companies that together market financial products or services to you.