Privacy Policy

Privacy Notice

Limited English Proficiency (LEP) Policy

Last updated July 18, 2024

General Policy Statement: Northern New Mexico School Employees Federal Credit Union is committed to a diverse and inclusive membership where all individuals feel valued through the credit union’s products and services. Title VI of the Civil Rights Act of 1964 prohibits recipients of federal financial assistance from discriminating based on national origin by, among other things, failing to provide meaningful access to products and services for individuals with Limited English Proficiency (LEP). An LEP person is an individual who does not speak English as their primary language and has limited ability to read, speak, write, and understand English. The credit union has taken and will take reasonable steps to ensure that individuals with LEP can communicate, either through written or oral language services, with members of our Staff and Management team who also come from diverse backgrounds and speak multiple languages.

Privacy Policy

Last updated July 19, 2024

This privacy notice for Northern New Mexico School Employees Federal Credit Union ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

Download and use our mobile application (Northern New Mexico School EFCU Mobile), or any other application of ours that links to this privacy notice

Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at membersupport@nmsefcu.org.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We may process sensitive personal information, when necessary, with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting

https://nmsefcu.org/contact-us

, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. CONTROLS FOR DO-NOT-TRACK FEATURES

10. DO NEW MEXICO RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

11. DO WE MAKE UPDATES TO THIS NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

14. OUR PRIVACY NOTICE THAT WE MAILTO OUR MEMBERS ANNUALLY.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names

• phone numbers

• email addresses

• mailing addresses

• usernames

• passwords

• contact preferences

• billing addresses

• debit/credit card numbers

• contact or authentication data

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• financial data

• biometric data

• credit worthiness data

• social security numbers or other government identifiers

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

• Push Notifications. We may request you to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information(such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2.  HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

3.  WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

4.  DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5.  IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in. If you are accessing our Services from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHAREYOUR PERSONAL INFORMATION?" above), in and other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8.  WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at

membersupport@nmsefcu.org

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

10. DO NEW MEXICO RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of New Mexico, you may be granted specific rights regarding access to and use of your personal information.

New Mexico PRDPL Consumer Privacy Rights and Data Protection Law Notice

Under the New Mexico Consumer Privacy Rights and Data Protection Law (PRDPL):

Source:

Privacy Rights and Data Protection Laws in New Mexico – State Regs Today

Privacy Rights and Data Protection Laws in New Mexico

Cynthia ChowFeb, 2024

1. What are the privacy rights of individuals in New Mexico according to state law?

According to state law in New Mexico, individuals have the right to privacy in several areas such as personal information, surveillance, and health information. This includes the right to control their own personal information, protection against unreasonable searches and seizures by law enforcement, and the confidentiality of their medical records.

2. How does New Mexico’s data protection law protect citizens’ personal information?

New Mexico’s data protection law, also known as the Data Breach Notification Act, aims to protect citizens’ personal information by requiring businesses and government entities to promptly notify individuals in the event of a data breach. This includes notifying affected individuals via mail, email, phone, or a conspicuous website posting. The law also requires that the Attorney General be notified in the event of a data breach affecting more than 1,000 residents. Additionally, businesses are required to implement and maintain reasonable security measures to safeguard personal information. Overall, New Mexico’s data protection law seeks to ensure transparency and accountability in the handling of personal information and provide recourse for individuals in the case of a data breach.

3. What requirements does New Mexico have for companies collecting and handling personal data from residents?

New Mexico has the Data Breach Notification Act, which requires companies to promptly notify any affected residents if their personal data is compromised in a data breach. They also have the New Mexico Privacy Act, which outlines specific requirements for companies collecting and handling personal data from residents, including ensuring that data is not collected or used without consent and providing individuals with the right to access and correct their personal information. Companies are also required to implement reasonable security measures to protect this data from unauthorized access or disclosure.

4. Are individuals in New Mexico able to access and control the use of their personal data by companies?

Yes, individuals in New Mexico have the right to access and control the use of their personal data by companies, as outlined in the state’s Data Breach Notification Act and Data Privacy Act. Under these laws, individuals have the right to request information about how their personal data is being collected and used by a company, as well as the right to opt-out of having their data shared with third parties. Companies are also required to take measures to protect personal data from breaches and unauthorized access.

5. How does New Mexico handle the storage and retention of personal data by companies?

New Mexico has laws in place that require companies to implement reasonable measures to protect the personal data of their customers or clients. Companies must also have policies and procedures in place for the appropriate storage and retention of personal data, as well as guidelines for securely disposing of such information when it is no longer needed. The state’s Data Breach Notification Act also mandates that companies must promptly notify affected individuals if their personal data has been compromised.

6. Do citizens in New Mexico have the right to know what personal information is collected about them by government agencies?

Yes, citizens in New Mexico have the right to know what personal information is collected about them by government agencies. This right is protected by the New Mexico Inspection of Public Records Act, which allows citizens to request access to government records, including personal information held by government agencies. Additionally, the state also has laws protecting the privacy of certain types of personal information, such as medical records and financial information.

7. What measures has New Mexico taken to protect citizens from cybercrimes and identity theft?

New Mexico has implemented several measures to protect its citizens from cybercrimes and identity theft. These measures include passing legislation such as the Cybersecurity for Government Act, which requires state agencies to implement baseline security standards for managing and protecting sensitive data. Additionally, the state has created a Cybersecurity Advisory Council to advise on strategies and policies for preventing and responding to cyber threats.
The New Mexico Attorney General’s office also offers resources and education on cybersecurity and identity theft prevention, including a dedicated hotline for reporting suspicious activity. The state also collaborates with federal agencies, such as the Department of Homeland Security and the Federal Bureau of Investigation, to combat cybercrimes.
Furthermore, New Mexico has implemented security protocols for its government systems and encourages businesses to do the same through tax incentives. It also conducts regular risk assessments and vulnerability testing to identify potential weaknesses in its networks.
Overall, New Mexico is continuously working towards strengthening its cybersecurity infrastructure and providing resources for individuals and businesses to protect against cyber threats.

8. Are there any restrictions on government surveillance and monitoring of citizens’ electronic communications in New Mexico?

Yes, the New Mexico Electronic Communications Privacy Act (NM ECPA) prohibits government entities from intercepting or accessing electronic communications of citizens without proper authorization, unless it falls under certain exceptions such as in cases of national security or with the consent of the individual. The NM ECPA also requires a warrant or court order for law enforcement to access private electronic communications. Additionally, citizens have the right to sue for damages if their privacy rights are violated.

9. Does New Mexico’s privacy rights laws apply to both private companies and government entities?

Yes, New Mexico’s privacy rights laws apply to both private companies and government entities.

10. How does New Mexico protect children’s online privacy rights?

New Mexico protects children’s online privacy rights through the Children’s Online Privacy Protection Act (COPPA) which regulates the collection and use of personal information from children under the age of 13. Additionally, New Mexico has implemented laws that require schools and companies to have specific policies in place for collecting and sharing student data, as well as providing parents with the right to access and delete their child’s information. The state also conducts regular audits and enforces penalties for violations of these laws.

11. Can private individuals in New Mexico sue companies for violating their privacy rights under state law?

Yes, private individuals in New Mexico have the right to sue companies for violating their privacy rights under state law.

12. Does New Mexico’s data privacy laws align with federal laws, such as the GDPR or CCPA?

As of now, New Mexico does not have any specific laws that directly align with the GDPR or CCPA. However, there is a proposed bill – the Data Breach Notification Act – that aims to strengthen data privacy protections in the state by requiring businesses to notify individuals in case of a data breach. This aligns with certain aspects of the GDPR and CCPA, but it is not a comprehensive alignment.

13. What penalties do companies face for violating state-level privacy laws in New Mexico?

Some potential penalties that companies could face for violating state-level privacy laws in New Mexico include fines, sanctions, or other forms of legal retribution. The specific consequences may vary depending on the severity and nature of the violation, as well as any previous infractions by the company. Additionally, companies may also face reputational damage and loss of consumer trust if their privacy practices are found to be in violation of state laws.

14. Are there any exceptions or loopholes in New Mexico’s privacy rights laws that allow for certain types of data collection without consent?

Yes, there are some exceptions and loopholes in New Mexico’s privacy rights laws that allow for certain types of data collection without consent. For example, law enforcement agencies can collect personal information without consent if it is part of an official investigation or to ensure public safety. Additionally, businesses may also be exempt from obtaining consent for data collection if it is necessary to provide a service or fulfill a contract with the individual. There are also exemptions for certain types of medical research, financial transactions, and internal business operations. However, these exceptions must comply with strict guidelines set forth by the state’s privacy laws.

15. How does New Mexico handle cross-border transfer of personal data under its privacy laws?

New Mexico handles cross-border transfer of personal data under its privacy laws by requiring organizations to obtain prior consent from individuals before transferring their personal data outside of the state. This includes providing information about the purpose and recipients of the data transfer. Additionally, New Mexico has strict data protection standards in place for the handling and storage of personal information, regardless of its location. Organizations are also required to implement security measures to protect personal data during cross-border transfers, including being subject to accountability and notification requirements in case of a data breach.

16. Are there any specific regulations or guidelines for companies on how they can use and share consumers’ personal information under state law in New Mexico?

Yes, there are specific regulations and guidelines for companies on how they can use and share consumers’ personal information under state law in New Mexico. These regulations are outlined in the New Mexico Electronic Data Privacy Act (NMEDPA) and the New Mexico Consumer Privacy Act (NMCPA). Both of these laws require companies to obtain consent from consumers before collecting, using, or sharing their personal information. They also mandate that companies implement security measures to protect this information from unauthorized access or disclosure. Additionally, under these laws, consumers have the right to request access to their personal information held by a company and to have it deleted if desired.

17. Can individuals opt out of targeted advertising based on their online activities and habits in New Mexico?

Yes, individuals can opt out of targeted advertising based on their online activities and habits in New Mexico. The state has a privacy law called the New Mexico Electronic Data Privacy Act (NEDPA), which allows residents to choose whether or not to allow companies to collect and use their personal data for targeted advertising purposes. This opt-out can be done through browser settings or by using a privacy protection tool.

18. What measures has New Mexico taken to ensure transparency and accountability of companies regarding their use of personal data?

Some measures that New Mexico has taken to ensure transparency and accountability of companies regarding their use of personal data include passing the Data Breach Notification Act, implementing the Personal Data Privacy Protection Act, and requiring companies to have a written privacy policy. The Data Breach Notification Act requires companies to notify individuals in the event of a data breach involving their personal information. The Personal Data Privacy Protection Act establishes regulations for companies’ collection, storage, and disclosure of personal data and requires them to obtain individuals’ consent for its use. Additionally, New Mexico has implemented laws that allow individuals to access and correct any inaccuracies in their personal data held by companies. These measures aim to increase transparency and hold companies accountable for their handling of personal data.

19. Are there any protections in place for employees’ personal data in New Mexico?

Yes, there are protections in place for employees’ personal data in New Mexico. The state has a data breach notification law that requires employers to notify their employees if their personal information has been compromised or stolen. Additionally, the state has regulations in place for how businesses must handle and protect sensitive employee information, such as social security numbers and financial data. Employers are required to take reasonable measures to secure this information and can face penalties if they fail to do so.

20. How does New Mexico address potential conflicts between privacy rights and national security concerns?

New Mexico addresses potential conflicts between privacy rights and national security concerns by following federal laws and regulations, such as the Privacy Act and the USA PATRIOT Act. Additionally, the state has its own measures in place to balance individual privacy with the need for effective national security, including strict data protection policies and safeguards for sensitive information. The state also ensures oversight and transparency through regular audits and reviews of agencies’ handling of private information. Furthermore, New Mexico allows individuals to voice their concerns or file complaints about potential violations of their privacy rights and takes appropriate actions accordingly.

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at

membersupport@nmsefcu.org

, by visiting

https://nmsefcu.org/contact-us

, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to act regarding your request, we will inform you of our decision and the reasoning behind it. If you wish to appeal our decision, please email us at

membersupport@nmsefcu.org

Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at

membersupport@nmsefcu.org

or contact us by post at:

Northern New Mexico School Federal Credit Union

614 Alta Vista Street

New Mexico, NM 87505

United States

13.  HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit:

 https://nmsefcu.org/contact-us

14.  Our Privacy Notice that we mail to members annually.

Northern New Mexico School Employees FCU (Current Privacy Notice) Rev. 9/20

13001025-DXPS0-P-1-090720 (DXPS01-E) Cuna LoanLiner