Liberty Bay Credit Union Mobile App Privacy Policy


Liberty Bay Credit Union (the “App”) helps you manage your money through your mobile device,
making it easy to manage your finances on the go.

The App allows you to:

● get real-time balances for your accounts
● manage your money
● view your transactions and statements
● make transfers
● pay your bills and manage billers
● deposit a check
● receive alerts

This Privacy Policy, in combination with other relevant privacy notices that we provide to you
(e.g., pursuant to financial privacy laws), inform you of the policies and practices regarding the
collection, use and disclosure of any personal information that we and our service providers
collect from or about users in connection with the App’s website and mobile application (the



Through your use of the Services, we may collect personal information from you in the
following ways:

(a) Personal Information You Provide to Us.

● We may collect personal information from you, such as your first and last name, address,
e-mail, telephone number, and social security number when you create an account.
● We will collect the financial and transaction information necessary to provide you with
the Services, including account numbers, payment card expiration date, payment card
identification, verification numbers, and transaction and payment history.
● If you provide feedback or contact us via email, we will collect your name and email
address, as well as any other content included in the email, in order to send you a reply.
● We also collect other types of personal information that you provide voluntarily, such as
any information requested by us if you contact us via email regarding support for the

(b) Personal Information Collected from Third Parties. We may collect certain information from
identity verification services and consumer reporting agencies, including credit bureaus, in order
to provide some of our Services.

(c) Personal Information Collected Via Technology. We and our service providers may
automatically log information about you, your computer or mobile device, and your interaction
over time with our Services, our communications, and other online services, such as:

● Some features included in digital banking on both our website and the Liberty Bay Credit
Union mobile app may request access to data located on the device used to access digital
banking. This may include biometric, camera (e.g. to utilize the mobile deposit capture
service), contacts, and location data. You will be prompted to allow access to the data,
and if you decline access, the feature requiring that data will not be fully functional.
● Device data, such as your computer’s or mobile device’s operating system type and
version, manufacturer and model, browser type, screen resolution, RAM and disk size,
CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language
settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and
general location information such as city, state or geographic area.
● Online activity data, such as pages or screens you viewed, how long you spent on a page
or screen, the website you visited before browsing to the Service, navigation paths
between pages or screens, information about your activity on a page or screen, access
times, and duration of access.
● Cookies, which are text files that websites store on a visitor’s device to uniquely identify
the visitor’s browser or to store information or settings in the browser for the purpose of
helping you navigate between pages efficiently, remembering your preferences, enabling
functionality, and helping us understand user activity and patterns.
● Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent
functionality but can store larger amounts of data, including on your device outside of
your browser in connection with specific applications.
● Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that
a webpage or email was accessed or opened, or that certain content was viewed or
● Location Information. If you have enabled location services on your phone and agree to
the collection of your location when prompted by the Services, we will collect location
data when you use the Services even when the app is closed or not in use; for example, to
provide our fraud detection services. If you do not want us to collect this information,
you may decline the collection of your location when prompted or adjust the location
services settings on your device.



(a) General Use. In general, we use your personal information collected through your use of the
Services to respond to your requests as submitted through the Services, to provide you the
Services you request, and to help serve you better. We use your personal information, in
connection with the App, in the following ways:

● facilitate the creation of, and secure and maintain your account
● identify you as a legitimate user in our system
● provide improved administration of the Services
● provide the Services you request
● improve the quality of experience when you interact with the Services
● send you administrative e-mail notifications, such as security or support and maintenance
advisories; and send surveys, offers, and other promotional materials related to the

(b) Compliance and protection. We may use your personal information to:

● comply with applicable laws, lawful requests, and legal process, such as to respond to
subpoenas or requests from government authorities

● protect our, your or others’ rights, privacy, safety, or property (including by making and
defending legal claims)
● audit our internal processes for compliance with legal and contractual requirements and
internal policies
● enforce the terms and conditions that govern the Service; and
● prevent, identify, investigate / deter fraudulent, harmful, unauthorized, unethical, or
illegal activity, including cyberattacks and identity theft.

(c) Creation of Non-Identifiable Data. The App may create de-identified information records
from personal information by excluding certain information (such as your name) that makes the
information personally identifiable to you. We may use this information in a form that does not
personally identify you to analyze request patterns and usage patterns to enhance our products
and services. We reserve the right to use and disclose non-identifiable information to third parties
at our discretion.



We disclose your personal information collected through your use of the Services as described

(a) In Accordance with Our Other Privacy Notices. Other than as described in this Privacy Policy
in connection with the App, this Privacy Policy does not apply to the processing of your
information by us or third parties with whom we share information.

(b) Third Party Service Providers. We may share your personal information with third party or
affiliated service providers that perform services for or on behalf of us in providing the App, for
the purposes described in this Privacy Policy, including: to provide you with the Services; to
conduct quality assurance testing; to facilitate the creation of accounts; to optimize the
performance of the Services; to provide technical support; and/or to provide other services to the

(c) Authorities and Others. Regardless of any choices you make regarding your personal
information, The App may disclose your personal information to law enforcement, government
authorities, and private parties, for the compliance and protection services described above.



The App may contain links to third party websites. When you click on a link to any other website
or location, you will leave the App and go to another site and another entity may collect personal
and/or anonymous information from you. The App’s provision of a link to any other website or
location is for your convenience and does not signify our endorsement of such other website or
location or its contents. We have no control over, do not review, and cannot be responsible for
these outside websites or their content. Please be aware that the terms of this Privacy Policy do
not apply to these outside websites. We encourage you to read the privacy policy of every
website you visit.



Google Analytics is a web analytics service offered by Google that tracks and reports website
traffic. Google uses the data collected to track and monitor the use of our Service. This data is
shared with other Google services. Google may use the collected data to contextualize and
personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by
installing the Google Analytics opt-out browser add-on. The add-on prevents the Google
Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google
Analytics about visits activity. For more information on the privacy practices of Google, please
visit the Google Privacy Terms web page:



You have several choices regarding use of information on the Services.

(a) How We Respond to Do Not Track Signals. Some web browsers transmit “do not track”
signals to the websites and other online services with which your web browser communicates.
There is currently no standard that governs what, if anything, websites should do when they
receive these signals. We currently do not act in response to these signals. If and when a standard
is established, we may revise its policy on responding to these signals.

(b) Access, Update, or Correct Your Information. You can access, update, or correct your
information by changing preferences in your account. For additional requests, please contact us.

(c) Opting Out of Email or SMS Communications. If you have signed-up to receive our email
marketing communications, you can unsubscribe any time by clicking the “unsubscribe” link
included at the bottom of the email or other electronic communication. Alternatively, you can opt
out of receiving marketing communications by contacting us at the contact information under
“Contact Us” below. If you provide your phone number through the Services, we may send you
notifications by SMS, such as providing you an authentication code when accessing online
banking from an unrecognized device. You may opt out of SMS communications by unlinking
your mobile phone number through the Services.

(d) Opting Out of Location Tracking. If you initially consented to the collection of geo-location
information through the Services, you can subsequently stop the collection of this information at
any time by changing the preferences on your mobile device. Please note, however, that if you
withdraw consent to our collection of location information, you may no longer be able to use
some features of the App.



We implement reasonable administrative, technical, and physical measures in an effort to
safeguard the information in our custody and control against theft, loss and unauthorized access,
use, modification, and disclosure. Nevertheless, transmission via the internet is not completely
secure and we cannot guarantee the security of your information.



The Services are not directed towards individuals under the age of 18, and we do not, through the
App, intentionally gather personal information about visitors who are under the age of 18. If a
child under 18 submits personal information to us through the App and we learn that the personal
information is the information of a child under 18, we will attempt to delete the information as
soon as possible.



This Privacy Policy is subject to occasional revision. We will notify you of any material changes
in its collection, use, or disclosure of your personal information by posting a notice on the
Services. Any material changes to this Privacy Policy will be effective thirty (30) calendar days
following notice of the changes on the Services. These changes will be effective immediately for
new users of the Services. If you object to any such changes, you must notify us prior to the
effective date of such changes that you wish to deactivate your account. Continued use of the
Services following notice of any such changes shall indicate your acknowledgement of such



If you have any questions or complaints about this Privacy Policy or The App’s data collection or
processing practices, or if you want to report any security violations to The App, please contact
The App by email at: or by phone 781.439.6500.

Reason we can share your personal informationDoes Liberty Bay Credit Union Share?Can you limit this sharing?
For 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.
For our marketing purposes To offer our products and services to you.YESNO
For joint marketing with other financial institutions.YESNO
For our affiliates’ everyday business purposes Information about your transactions and experiencesNOWE DON'T SHARE
For our affiliates’ everyday business purposes Information about your creditworthiness.NOWE DON'T SHARE
For non affiliates to market to you.NOWE DON'T SHARE