Privacy Policy of

Partners Federal Credit Union

Effective: 04.01.2009

Partners Federal Credit Union
PO Box 25020
Anaheim, CA 92825-5020
800.948.6677
PartnersFCU.org

Partners Federal Credit Union is committed to protecting the privacy of our Members. Partners Federal Credit Union has adopted this privacy policy.

Reference to "we", "us" and "our" refers to Partners Federal Credit Union. References to "you" or "your" shall mean the Members of Partners Federal Credit Union. Throughout this notice the word "information" refers to personal information about you that may not be publicly available. In the course of providing services to you, we collect information about you. Some of this information is nonpublic personal information. We do not sell your information but we share some of the information with our service providers and others in order to better serve you. If you have any questions after reading this Privacy Policy, please contact us at 800.948.6677.

Information We Collect About You
To provide products and services to you, comply with government regulations, improve our products and services and to better understand your financial needs we collect and maintain information about you. We collect information:

• you provide on applications and other forms (for example, name, address, social security number, assets and income);
• about your transactions with us, or others including those companies that work closely with us to provide you with diverse financial products and services (for example, your account balance, payment history, parties to transactions and credit card usage);
• about your credit history from a credit reporting agency (for example, your credit worthiness and credit history);
• obtained when verifying the information you provided on an application or other forms (this may be obtained from your current or past employers or from other institutions where you conduct financial transactions);
• we may obtain from consumer purchasing and census data providers to develop competitive marketing programs for our Members; and
• recorded in our Web servers standard log file. Like most standard Web site servers we use log files. This includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user's movement in the aggregate, and gather broad demographic information for aggregate use. Partners IP address does not link to personally identifiable information.

We may disclose all of the information we collect, as described above, as permitted by law and in accordance with this Privacy Policy.

Information We Disclose to Others to Provide You with Products and Services
Partners Federal Credit Union may disclose information about you to nonaffiliated third parties with whom we have written joint marketing agreements to offer you a broader array of products and services. Joint marketing agreements include confidentiality provisions to protect your information. These nonaffiliated third parties include:

• financial service providers such as insurance companies, mortgage service companies and securities broker-dealers;
  
• non-financial companies, such as consumer reporting agencies and retailers.

Disclosure of Information to Parties That Provide Services to Us
In order to administer and provide our Members with competitive products and services, we may disclose all of the information we collect, to companies that perform marketing or other services on our behalf or to other financial service providers with whom we have joint marketing agreements (for example, companies providing Web site loan applications, check and statement printing companies, companies that help us process transactions you request following your instructions, protect the security of your financial records, or conduct our operations). We have written agreements with these third parties that include confidentiality provisions to protect your information.

Other Legally Permitted Disclosures
We may also disclose information about you under circumstances as permitted or required by law. These disclosures typically include disclosures to consumer and credit reporting agencies or to comply with a judicial proceeding, court order, or legal process served on us.

Disclosure of Information about Former Members
If you decide to terminate your membership with us, we will not share information we have collected about you, except as may be permitted or required by law.

How to Opt-Out or Stop Certain Disclosures About You
If you prefer that we do not disclose nonpublic information about you to nonaffiliated third parties, you may opt-out of the following disclosures, that is, you may direct us not to make those disclosures (other than disclosures permitted by law); and/or sharing your personal information for non-affiliates to market to you. We may determine from time to time that there are other products or services that may be of interest to our Member. In order to offer these products or services we will provide some nonpublic personal information to other third party providers on a confidential basis, with contractual restrictions on the use of the information. If you elect to exercise your opt-out right, we will not disclose your nonpublic personal information to these other third parties. You may exercise your opt-out right at any time and may revoke it at any time. If you have a joint account the opt-out instruction given by one participant will affect all participants of the account. If you do not act, the nonpublic personal information will be disclosed to nonaffiliated third parties as discussed in this Privacy Policy.

If you wish to opt-out of one or more of the types of disclosures set forth in the preceding paragraph, you may do so by:

• calling the following toll free number, 800.948.6677.
• sending a secured message through PartnersLink® Online Banking at PartnersFCU.org
• sending your signed written request to:
  Partners Federal Credit Union
  Attn: Operations Department
  P.O. Box 25020
  Anaheim, CA 92825-5020

Your written request needs to include the name of the organization the opt-out request is addressed to: Partners Federal Credit Union, your account number, name, address, telephone number, the current date, the type of disclosure(s) you wish to opt-out of and the request must be signed.

If you have communicated your privacy election to us in the past, it is not necessary to do so again until you receive a renewal notice. If you choose to limit our sharing of your personal information for marketing purposes, you will receive a renewal notice for this use for marketing in 5 years. You may opt-out of these disclosures at any time. This opt-out by law, will not apply to disclosures that are legally permitted, including disclosures we make to companies performing or processing a financial product or service that you may request or is necessary to maintain your account. Once we receive your request, we have a reasonable amount of time to stop the disclosures. You may always contact us for assistance if you wish to later revoke your opt-out election.

Fair Credit Reporting Act Disclosure
As permitted by law, Partners Federal Credit Union may share your information for direct marketing. If an opt-out is received, your information will not be shared after receipt of the opt-out request. As required by law you are hereby notified that a negative credit report reflecting your credit record may be submitted to a credit-reporting agency if you fail to fulfill the terms of your obligations.

How We Protect Your Information
We strive to protect your information by:

• setting policies and procedures for the careful handling of your information;
• restricting access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you;
• requiring service providers who do business with us to comply with privacy laws;
• monitoring our Web site through recognized privacy and security programs such as Multi-Factor Authentication;
• maintaining physical and electronic safeguards that comply with federal regulations to guard your nonpublic personal information;
• training our employees in the importance of maintaining confidentiality and Member and client privacy; and
• continuously testing and updating our technology and systems to assure the protection of your personal information.

Children's Online Privacy
We do not knowingly solicit or collect data from children under 13, from our Web site without obtaining verifiable consent from their parents. We recognize that protecting children's identities and online privacy is important. Should a child whom we know to be under 13 send us personal information, we will only use that information to respond directly to that child, seek parental consent, or provide parental notice. We are not responsible for the data collection and use practices of nonaffiliated third parties to which our Web site might link.

Web Site "Cookies"
"Cookies" are small pieces of information that are stored on your hard drive as a file. We use session cookies to verify who you are while using PartnersLink, Partners Federal Credit Union's online banking service. Session cookies are necessary for the security of your account and are used for authentication only.

Legal Disclaimer
We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on us.

Changes to Our Privacy Policy
We reserve the right to revise our Privacy Policy as our business needs change or as required by law. If we revise our policy, we will provide our active Members and current clients with a copy of our new policy by separate mailing or include it with your account statement or you can retrieve a copy at your convenience at PartnersFCU.org.

Notice to California Residents:
We will provide a separate short form notice describing the rights of California residents to opt-out under California law. We will only share information as required or permitted by law.

What Members/Clients Can Do to Help
Partners Federal Credit Union and PFCU Financial Services, LLC are committed to protecting the privacy of its Members and clients. You can help by:

• protecting your account numbers, card numbers, PINs (personal identification numbers) and passwords. Never keep your PIN with your ATM, debit or credit card, which can provide access to your accounts if your card is lost or stolen.
  
• using caution when disclosing your account numbers, social security numbers, etc. to other persons. If someone calls you, explains the call is on behalf of the Credit Union and asks for your account number, you should beware. Official Credit Union employees will have access to your information and will not need to ask for it.
  
• keeping your information current. It is important that we have current information on how to reach you. If we detect potentially fraudulent or unauthorized activity or use of an account, we will attempt to contact you immediately. If your address or phone number changes, please let us know.

How to Maintain the Accuracy of Your Information
We strive to ensure that our records contain accurate information about you. If you see any inaccuracies in your information or statements from Partners Federal Credit Union, please contact us at 800.948.6677 or write to us at Partners Federal Credit Union, P.O. Box 25020, Anaheim, CA 92825-5020. We will promptly investigate and make any necessary changes to update your records. However, in order to protect your information, we may ask to verify your identity and for other details to respond to your request.

Protecting Your Identity
Identity theft is one of the fastest growing crimes in America today. We understand the implications identity theft can have and take the appropriate steps to reduce the chance that identity thieves can damage the credit reputations of our Members. If you think your identity has been stolen, affecting any of your accounts with Partners Federal Credit Union contact us immediately.

You should also contact the three major consumer credit reporting agencies and have them place a fraud alert on your file.

For additional information on identity theft, contact the Federal Trade Commission at www.consumer.gov/idtheft or call their hotline at 1.877.IDTHEFT (438.4338)