PRIVACY POLICY
Members Trust Company Privacy Notice
Last Updated/Effective Date: December 31, 2023
Members Trust Company (“MTC,” “we,” “us,” or “our”) respects your privacy. This Privacy Notice describes the processing of Personal Information (defined below) that is provided, collected, or disclosed on the websites, applications, and other platforms that link to this Privacy Notice (“Sites”), including when you apply for a job with us. It also describes rights you may have under applicable laws.
This Privacy Notice is available to consumers with disabilities. To access this Privacy Notice in an alternative downloadable format, please click here.
1) Personal Information We Collect
We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. The types of Personal Information we collect may include:
General Information – If you contact us via our Sites, we may collect your contact information, including your first and last name, email address, credit union affiliation, state. We may also collect general information about your interest in our trust services, including the approximate value of assets you are interested in investing in a trust and your stage of interest in seeking trust services.
Usage Information – When you use our Sites, we may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the website you visited before coming to our Sites), domain names associated with your internet service provider, and any other information regarding your interaction with our Sites.
Employment Information – If you apply for employment with us, we will collect Personal Information related to your potential employment, including your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
Communication Information – We may collect Personal Information contained within your communications with us and any files provided to us via email, chat functionality, telephone, or otherwise. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality.
2) How We Collect Personal Information
Directly From You – We collect Personal Information that you provide to us, for example, if you choose to contact us, request information from us, or sign up to receive updates.
Through Online Tracking Technologies – We use cookies and similar technologies to collect Personal Information related to activity on our Sites. For additional information regarding our use of these technologies, see the Cookies and Tracking Technologies section below.
3) How We Use Personal Information
To the extent permitted by applicable law, we use Personal Information:
For internal research and development, such as testing and verifying the quality of our Sites and improving the quality of our Sites.
For marketing, such as sending information about our services, including using your information to send you messages, notices, newsletters, or surveys.
For communicating with you, such as responding to your questions and comments.
For legal, security, or safety reasons, such as protecting our and our clients’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business’ assets, or another corporate transaction, including bankruptcy
If you are applying for employment with us, we also use Personal Information to process your job application, to verify the information you have provided in your application, conduct interviews, perform background and reference checks, to communicate with you and answer your questions, to confirm your eligibility for employment, and improve our recruiting processes. We may also save your Personal Information for future employment opportunities with us.
4) How We Use Personal Information
We may disclose your Personal Information in the following circumstances:
Service Providers – We disclose your Personal Information with third party service providers as necessary to enable them to support our Sites or other aspects of our business.
Business Partners – We may disclose Personal Information with trusted business partners or corporate affiliates. For example, we may disclose your Personal Information with a company whose products or services we think may be of interest to you.
Legal Obligation or Safety Reasons – We may disclose Personal Information to a third party when we have a good faith belief that such disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of MTC, its employees and clients, or the public against harm.
Merger or Change of Control – We may disclose Personal Information to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving a change of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where legally required, we will give you prior notice prior to such disclosure.
5) Cookies and Other Tracking Technologies
We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Sites. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Sites, to enhance your experience through personalization, and to help us better understand the features of our Sites that you and other users are most interested in.
We allow or enable third parties to collect Personal Information in order to provide their interest-based advertising services, and we use Google Ads and other third parties to serve ads for our services across various websites. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of your data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of our Sites.
We use analytics services, including Google Analytics, to assist us with analyzing our Site traffic. These services utilize cookies and other technologies that collect your Personal Information. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ websites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of our Sites may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time.
6) How Long We Keep Your Personal Information
We will retain each category of your Personal Information for as long as necessary to fulfill the purposes described in this Privacy Notice, unless otherwise required by applicable laws. Criteria we will use to determine how long we will retain your Personal Information include whether we need your Personal Information to provide you with information you have requested; we continue to have a relationship with you; we have a legal right or obligation to continue to retain your Personal Information; we have an obligation to a third party that involves your Personal Information; our retention or recordkeeping policies and obligations dictate that we retain your Personal Information; or we have another business purpose for retaining your Personal Information.
7) How We Protect Personal Information
We use commercially reasonable efforts to protect the confidentiality and security of Personal Information. However, despite these efforts to store Personal Information in a secure environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems.
8) International Use of our Sites
Our Sites are hosted in the United States. If you are visiting our Sites from outside of the United States, please note that by providing your Personal Information, it is being transferred to, stored, collected, or processed in the United States, where our servers are located and operated.
9) Children’s Privacy
We do not knowingly collect or solicit any Personal Information from children under the age of 13 without verified written parental consent. In the event that we learn that we have collected Personal Information from a child under the age of 13, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at marketing@memberstrust.com.
10) Links to Third-Party Websites
We are not responsible for the practices employed by any websites or services linked to or from our Sites, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will handled in accordance with the applicable third party’s privacy notice.
11) Notice to California Residents
This section applies to our collection and use of Personal Information if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), where “Personal Information” has the definition set forth in the CCPA.
MTC makes the following disclosures regarding the Personal Information it has collected within the 12-month period preceding the Effective Date of this Privacy Notice:
Categories of Personal Information
We may collect the following categories of Personal Information as specified in the CCPA:
Identifiers
Personal Information, as defined in the California customer records law
Characteristics of protected classifications under California or federal law
Internet or other similar network activity
Inferences drawn from other Personal Information
Professional or employment-related information
Sources of Personal Information
We collect Personal Information from the categories of sources detailed in the How We Collect Personal Information section above.
Use of Personal Information
We collect Personal Information for the business and commercial purposes detailed in the How We Use Personal Information section above.
Disclosure of Personal Information
The categories of third parties to whom we disclose Personal Information for a business or commercial purpose are detailed in the How We Disclose Personal Information section above. Generally, we do not “sell” or “share” Personal Information within the meaning of the CCPA, and specifically, we do not knowingly “sell” or “share” the Personal Information of minors under the age of 16.
12) Your Privacy Rights and How to Exercise Them
Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws:
Access – You may have the right to know what Personal Information we have collected about you and to access such data.
Data portability – You may have the right to receive a copy of your information in a portable and readily usable format.
Deletion – You may have the right to delete your Personal Information that we have obtained, subject to certain exceptions.
Correction – You may have the right to correct inaccuracies in your Personal Information.
To opt out of marketing emails, please email us at marketing@memberstrust.com or by following the instructions included in the email or text correspondence. Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.
To exercise any of the privacy rights afforded to you under applicable data protection laws, please submit a request to us by one of the following methods:
Calling us toll free at (888) 727-9191
E-mailing us at marketing@memberstrust.com
You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Privacy Notice which means we will not deny services to you, provide different prices or rates for services to you, or provide a different level or quality of services to you. Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information.
We must verify your identity before fulfilling your requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making a request on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.
We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.
Other California Privacy Rights
Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us using the information in the Contact Us section below. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
13) Changes to this Privacy Notice
Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. We will provide you notice if material changes are made. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to our Sites.
14) Contact Us
If you have any questions about our practices or this Privacy Notice, please contact us at marketing@memberstrust.com. You may also write to us at 14055 Riveredge Drive, Suite 525, Tampa, FL 33637.
