O&R Utilities EFCU Mobile Privacy Policy
  Last Updated: July 30, 2025
  O&R Utilities  EFCU Mobile App (the “App”)– powered  by Fiserv – helps you control  your credit and/or debit cards 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
- manage cards
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 “Services”).
THE TYPES OF INFORMATION WE COLLECT IN THE APP
Through your use of the Services,  we may collect personal information from you in the following ways:
  - 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 Services.
- 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.
  
    - 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:
      - 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., WiFi, 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 clicked.
- 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.
HOW WE USE YOUR INFORMATION COLLECTED IN THE APP
  
    - 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 Services. 
 
  
    - 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 and deter fraudulent, harmful, unauthorized, unethical or illegal activity,  including cyberattacks and identity theft. 
- 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 in our discretion.
DISCLOSURE OF YOUR PERSONAL INFORMATION
  We disclose  your personal information collected through your use of the Services  as described below.
  
    - 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.
- 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 App.
- 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.
LINKS TO OTHER SITES
  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.
  YOUR CHOICES REGARDING YOUR INFORMATION
 
  You have several choices  regarding use of information on the Services.
  
    - 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 take action in response to these signals. If  and when a standard is established, we may revise its policy on responding to  these signals.
- 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.
- 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 provide a fraud alert. You may opt out of SMS communications by unlinking  your mobile phone number through the Services.
- 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.
SAFEGUARDS AND RETENTION
  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.
  A NOTE ABOUT CHILDREN
  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.
  PRIVACY POLICY UPDATES
  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 changes.
 
CONTACT US
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: info@orutilfcu.org or by  mail at:
  ORUEFCU PO  Box 470
  Monroe, NY 10949