PRIVACY AND DISCLOSURE POLICY
The directors, management, and staff of Union Federal Savings Bank (hereafter “the Bank”,
“we”, “us” or “our”) are concerned about and respect the privacy of customers' and consumers'
personal financial information. We understand that our customers furnish sensitive information to
the Bank in the course of our daily business, and the Bank is committed to treating such
information responsibly. We know that our customers expect privacy and security for their
personal and financial affairs.
The Bank will take all the necessary steps to safeguard sensitive information that has been
entrusted to us by our customers. The following privacy policy and disclosure outlines our
practices regarding personally identifiable financial information for Bank customers, former
customers, and consumers (individually and collectively referred to hereinafter as “you” or “your”).
This privacy policy and disclosure applies to both the Bank and its wholly-owned affiliate, UFSB
Private Loan SPV, LLC (“UFSB SPV”). From time to time, the Bank may elect to transfer loans
to UFSB SPV for internal finance and accounting purposes. Any such transfer will have no effect
on you or the servicing of your loan. If we do transfer your loan to UFSB SPV, then as used in
this privacy policy and disclosure, the terms “we”, “us”, “our” and “Bank” include UFSB SPV.
TYPES OF INFORMATION THE BANK COLLECTS
The Bank collects nonpublic personal information about you from many sources, including:
- Information we receive from you on applications or other forms, such as your name, address, social security number, assets, and income
- Information about your transactions with our affiliates, others, or us (such as your
account balances and payment history)
- Information we receive from third parties, such as a consumer reporting agency
- Nonpublic personal information does not include that which is available from government
records, widely distributed media, or government-mandated disclosures.
TYPES OF INFORMATION THE BANK DISCLOSES
Information That We Share With Our Affiliates
The Bank may disclose nonpublic personal information, as described above, about you to our
family of affiliated businesses (our “affiliates”) in the following ways:
- The Bank is permitted by law to share information about our experiences or transactions
with you or your account (such as your deposit or loan account performance or
transactions) with our affiliates. Since the disclosure of your nonpublic personal
information with our affiliates in the manner described herein is permitted by applicable
law, it is not subject to your right to opt-out as described in this policy.
- We may also share additional information about you or your loan (such as information
from your loan application and information from consumer reporting agencies) with our
affiliates. You may direct us not to disclose the information to our affiliates that does not
relate solely to our or our affiliates’ experiences or transactions with you or your
account(s) (such as information you provide to us on applications or other forms, or
information from a consumer reporting agency) by returning the completed opt-out form
that is attached to this policy.
Information That We Share With Third Parties
A. Sharing With Nonaffiliated Third Parties (Unless You Opt-Out)
The Bank may also share your nonpublic personal information with nonaffiliated third parties,
including (but not limited to):
- Mortgage banking companies
- Insurance companies
- Brokerage companies
- Finance companies
You may direct us not to disclose your nonpublic personal information to these types of third
parties by returning the completed opt-out form that is attached to this policy.
If you live in California, North Dakota, Vermont, or any other state which prohibits disclosure of nonpublic personal information about you to nonaffiliated third parties without your consent, we
will not disclose your nonpublic personal information to nonaffiliated third parties (other than the
disclosures described in B and C, below).
B. Joint Marketing Agreements
The Bank is permitted by law to disclose nonpublic personal information about you to
nonaffiliated third parties that perform marketing services on our behalf, including financial
institutions with which we have joint marketing agreements. However, the Bank will not provide
your nonpublic personal information to nonaffiliated third parties for the purpose of their
independent telemarketing or direct mail marketing of any non-financial products or services.
Since the disclosure of your nonpublic personal information as described in subsection (B) is
permitted by applicable law, it is not subject to your right to opt-out as described in this policy.
C. Other Disclosures As Permitted by Law
The Bank is also permitted by law to disclose nonpublic personal information about you to
nonaffiliated third parties in certain circumstances. For example, we may disclose nonpublic
personal information about you to:
- Third parties that assist us in servicing your account(s) with us
- Government agencies and others in response to subpoenas
- Guarantors or potential purchasers of your account(s)
- Consumer reporting agencies
Since the disclosure of your nonpublic personal information as described in subsection (C) is
permitted by applicable law, it is not subject to your right to opt-out as described in this policy.
SAFEGUARDING CUSTOMER INFORMATION
At the Bank we protect consumer privacy by ensuring that only employees who have a business
reason for knowing information have access to it. We have appointed a financial privacy
coordinator who is responsible for maintaining internal procedures to ensure that our customers'
information is protected. For example, only employees who work in the loan origination or
operations departments can access information in loan files.
All employees have a copy of this policy and are trained at least annually regarding the
importance of safeguarding customer information. The financial privacy coordinator, the human
resources director, and the appropriate department manager will take disciplinary action against
any employee who violates the Bank's privacy policy and procedures.
The Bank maintains physical, electronic, and procedural safeguards that comply with federal
regulations to guard your nonpublic, personal information.
If we change our policy or practice by, for example, adding a category of information that
we will disclose to a third party, we will notify existing customers and give them an
appropriate time period to opt-out of the disclosure.
YOUR RIGHT TO OPT-OUT
Unless the disclosure is permitted by applicable law, you have the right to instruct the Bank not to
share your nonpublic personal information with its affiliates and nonaffiliated third parties. To
exercise this right, please complete and return the form attached to this policy. You may exercise
this right at any time.
If you sign the opt-out notice at the time your account is opened or application processed, we will
honor your request immediately. If you notify the Bank after your account is opened or
application processed, we agree to stop sharing your information within a reasonable time.
If you opt-out at a later time, please include the following information in your request:
- Your full name, Social Security number and your mailing address
- The names and Social Security numbers of all persons authorized to use your accounts
Click here for our opt-out form
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