1. The Information We Collect From Children, How We Use It, and How and When We Communicate With Parents
TCU’s website and application offers a variety of services, including some that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to provide the service requested by the child, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.
Parents cannot submit online applications to open accounts for children under the age of 13. All such applications must be submitted in person at a branch. Once a Family Banking account has been opened for a child under the age of 13, that child will have the ability to access their account through TCU’s website and TCU’s mobile application. Using TCU’s website or mobile application, members, including children under the age of 13, can change their personal account information, including:
- A home or other physical address including street name and name of a city or town;
- Online contact information;
- A screen or user name that functions as online contact information;
- A telephone number
We may also collect information from children by the following means:
TCU’s mobile application allows for push notifications. Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use. Push notifications may collect a device identifier.
TCU’s website and application may collect geolocation information that is specific enough to equate to the collection of a street address.
When users interact with us, certain information may automatically be collected to make our website and application more useful to our members and for various purposes related to our business. Examples include the type of computer operating system, the user’s IP address or mobile device identifier, the web browser, the frequency with which the user visits various parts of our website or mobile application, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers. This information may be collected by TCU or by a third party. This data is principally used for internal purposes only, in order to:
- provide users with access to features and activities on our website and mobile application
- customize content and improve our website and mobile application
- conduct research and analysis to address the performance of our website and mobile application
- generate anonymous reporting for use by TCU
The list of third-party operators who collect persistent identifiers on our sites and applications may be found here:
- Access Softek
Please contact us at the mailing address, email, or phone number below with questions about the operators’ privacy policies and collection and use practices:
Technology Credit Union
2010 North First Street
San Jose, CA 95131
Email: [email protected]
About Verifiable Parental Consent:
Because TCU’s website and mobile application allow children to provide personal information online, COPPA requires that we first seek a parent or guardian’s consent to collect that information before opening a Family Banking account for any child under the age of 13. You may provide your consent by signing the Consent to Collect Personal Information From Your Child form which is available to download here (PDF), at any TCU branch and returning it to a TCU branch in person. If a parent or guardian does not consent, the application will be denied. Download COPPA Direct Notice to Parents form (PDF).
2. When Information Collected From Children Is Available To Others
TCU may share or disclose personal information collected from children in a limited number of instances, including the following:
- We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
- We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
3. Parental Choices and Controls
At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
We use two methods to allow parents to access, change, or delete the personally identifiable information that we have collected from their children:
- Parents can request access to and delete their child’s personal information by logging on to the child’s account. Parents will need their child’s username and password.
- Parents can contact TCU directly at 800-553-0880.
In any correspondence to TCU such as e-mail or mail, please include the child’s username and the parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.