Privacy Policy

NAFT Federal Credit Union has a duty to protect the confidential nature of nonpublic personally identifiable financial information [as defined in 12 CFR 716.3 (q)] our members provide regarding their financial transactions with us. Except as provided in NAFT Federal Credit Union's Privacy Notice Disclosure to Members, our agreements with our members, reporting to a credit reporting agency regarding member's loans and accounts, or as permitted or required by applicable state or federal law, the credit union will not release member nonpublic personal information to any person. NAFT Federal Credit Union may release specific information to a specific third party only upon written request from an authorized account holder, borrower, co-borrower or guarantor.

To develop, implement and revise this policy as needed, the board of directors appoints the Senior Vice President as the Financial Privacy Coordinator.

The Financial Privacy Coordinator is responsible for the development and maintenance of procedures that ensure the credit union's compliance with the obligations described in this Policy. In this regard, the Financial Privacy Coordinator will ensure that the credit union develops procedures that safeguard the security and confidentiality of member information: protect against any anticipated threats or hazards to the security or integrity of such records: and protect against Unauthorized access to or use of such records or information that would result in substantial harm to any member.

NAFT FEDERAL CREDIT UNION PRIVACY NOTICE DISCLOSURE TO MEMBERS

The directors, management, and staff of NAFT Federal Credit Union are concerned about and respect the privacy of our members personally identifiable financial information. We understand that our members furnish sensitive information to the credit union in the course of daily business, and the credit union is committed to treating such information responsibly. We know that our members expect privacy and security for their personal and financial affairs.

NAFT Federal Credit Union will take all the necessary steps to safeguard sensitive information that has been entrusted to us by our members. The following Privacy Policy outlines practices regarding personally identifiable financial information for members and others with which we establish a "member relationship" pursuant to 12 CFR 716.3(q) of NCUA's Rules and Regulations. NAFT Federal Credit Union's policy regarding security of member information is set forth in its Member Financial Records Privacy Policy.

 TYPES OF INFORMATION THE CREDIT UNION COLLECTS

At NAFT Federal Credit Union, we collect nonpublic personal information from many sources. The credit union collects nonpublic personal information directly from members, joint owners, co-borrowers, and guarantors on various applications, deposit account applications, and requests for information about accounts or products and services.

 The credit union also collects information as a result of transactions between the credit union and such individuals and as a result of providing our products and services. This includes transaction information from share drafts (checks), debit cards, credit cards, automated teller machine (ATM) cards, and electronic transfers (for example, home banking or automated clearinghouse (ACH) transactions).

 Nonpublic personal information does not include information the credit union obtains from records, widely distributed media, or government-mandated disclosures.

 TYPES OF INFORMATION THE CREDIT UNION DISCLOSES.

NAFT Federal Credit Union does not now, nor does it presently intend in the future, to disclose any personally identifiable financial information to any non-affiliated or affiliated third party. By law, the credit union may disclose certain personally identifiable financial information without allowing members the right to opt out of the credit union's sharing agreements in the following circumstances:

 a. With the consent or at the direction of the consumer, provided that the consumer has not revoked the consent or direction.

b. To protect the confidentiality or security, of our records pertaining to the consumer, service, product or transaction.

c. To protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability.

d. For required institutional risk control or for resolving consumer disputes or inquiries.

e. To persons holding a legal or beneficial interest relating to the consumer.

f. To persons acting in a fiduciary or representative capacity on behalf of the consumer.

g. To provide information to insurance rate advisory organizations, guaranty funds or agencies, agencies that are rating the Credit Union, persons that are assessing our compliance with industry standards, and our attorneys, accountants, auditors and examiners.

h. To the extent specifically permitted or required under other provisions of law in accordance with the Right to Financial Privacy Act of 1978 (12 U.S.C. 3401 et seq.), to law enforcement agencies (including a federal functional regulator, the Secretary of the Treasury, with respect to 31 U.S.C. Chapter 53, Subchapter II (Records and Reports on Monetary Instruments and Transactions) and 12 U.S.C. Chapter 21 (Financial record keeping), a state insurance authority, with respect to any person domiciled in that insurance authority's state that is engaged in providing insurance, and the Federal Trade Commission), self regulatory organizations, or for an investigation on a matter related to public safety.

i. To a consumer reporting agency in accordance with the Fair Credit Reporting Act (15 U.S.C. 1681 etseq.).

j. From a consumer report reported by a consumer reporting agency.

k. In connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of business or operating unit if the disclosure on nonpublic personal information concerns solely consumers of such business or unit.

1. To comply with federal, state or local laws, rules and other applicable legal requirements.

m. To comply with a properly authorized civil, criminal or regulatory investigation, or subpoena or summons by federal, state or local authorities.

n. To respond to judicial process or government regulatory authorities having jurisdiction over us for examination, compliance or other purposes as authorized by law.

o. To companies that perform transaction processing for the credit union:

 1. Disclosures in connection with the servicing or processing a financial product or service that a consumer requests or authorizes.

2. Disclosures in connection with maintaining or servicing the consumer's account with us, or with another entity as part of a private label credit card program or other extension of credit on behalf of such entity.

3. Disclosures in connection with a proposed or actual securitization, secondary market sales (including sales of servicing rights) or similar transaction related to a transaction of the consumer.

4. Disclosures which are otherwise necessary to "effect, administer, or enforce" a transaction that a consumer requests or authorizes, including:

 (a) Disclosure which is required, or is one of the lawful or appropriate methods to enforce the credit union's rights or the rights of other persons engaged in carrying out the financial transaction or providing the product or service;

(b) Disclosure which is required, or is a usual, appropriate or acceptable method to carry out the transaction or the product or service business of which the transaction is a part, and record, service or maintain the consumer's account in the ordinary course of providing the financial service or financial product;

(c) Disclosure which is required, or is a usual, appropriate or acceptable method to administer or service benefits or claims relating to the transaction or the product of service business of which it is a part;

(d) Disclosure which is required, or is a usual, appropriate or acceptable method to provide a confirmation, statement or other record of the transaction or information on the status or value of the financial service or financial product or the consumer or the consumer's agent or broker;

(e) Disclosure which is required, or is a usual, appropriate or acceptable method to accrue or recognize incentives or bonuses associated with the transaction that are provided by us or any other party;

(f) Disclosure in connection with the authorization, settlement, billing, processing, clearing, transferring, reconciling or collection of amounts charged, debited, or otherwise paid using a debit card or other payment card, check or account number, or by other payment means;

(g) Disclosure in connection with the transfer or receivables, accounts or interest therein, or;

(h) Disclosure in connection with the audit of debit, credit or other payment information.

SAFEGUARDING MEMBER INFORMATION

NAFT Federal Credit Union is dedicated to protecting member privacy and to maintaining the confidentiality of member's financial information. The credit union has appointed a Financial Privacy Coordinator, who is responsible for maintaining internal procedures, to ensure that our members' information is protected.

All employees have a copy of this policy and the credit union's Member Financial Records Privacy Policy and are trained regarding the importance of safeguarding member information. In addition, all employees are trained on the credit union's confidentiality policy and sign a statement that they understand and agree to hold any and all information related to the credit union in the strictest confidence.

If we change our policy or practice by, for example, adding a category of information that will be disclosed to a third party, the credit union will notify existing members and give them an appropriate time period to opt out of the disclosure.