Last updated: February 24, 2021
Compeer Financial, ACA/FLCA/PCA ( “Compeer Financial”, “us”, “we” or “our”) operates www.compeer.com and various subdomains, including but not limited to pages.compeer.com, rates.compeer.com and my.compeer.com (collectively, the "Site"). This Privacy Statement details our Personal Information collection, use and disclosure practices.
Protecting your privacy and confidentiality is our top priority. Our employees are informed of their responsibility to protect your Personal Information and are governed by strict standards of conduct, which prohibit unauthorized use of your information. Security procedures and internal controls are in place to protect your privacy and Personal Information.
Personal Information includes, but is not limited to:
- Account information
- Account numbers
- Client number
- Credit card numbers
- Loan number
- Personal identification numbers (PINs)
- Phone number
- Social Security numbers or tax identification numbers
By visiting the Site, you are accepting the terms of this Privacy Statement. If you do not agree to the terms of the Privacy Statement, please do not access or use the Site.
Through your use of the Site we may collect certain Personal Information that can be used to contact or identify you.
Information you provide
We collect the Personal Information that you provide to us, including certain Personal Information from you, such as contact information (such as name and email), date of birth, Social Security number, and bank account information. If you provide us contact information to learn more about our services or choose to send us a message with information about yourself, we will maintain records of your correspondence. This may include any of your questions, comments, or suggestions and our responses.
Information Provided by Third Parties
We may receive certain Personal Information about you from third parties. For example, we may receive information about your credit history from a credit reporting agency or income information from your employer. Please note that if you choose to apply for a loan online, you are authorizing us to obtain credit history information needed to make lending-related decisions.
Device and Usage Information
The Site automatically collects technical information through your use of the Site, such as the
- Usage Information: We collect certain information automatically through your use of the Site, such as which of the pages on our Site that you access, the time and date of access, the frequency of access, and what you click on while on our Site.
- Location Information: When you use the Site, we may collect information about your actual location. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points, and cell towers.
- Device Information: We may collect information about the device you are using, such as hardware model, operating system, application version number, browser type and version, and IP addresses.
- Mobile Device Information: In addition to the device information listed above, when you access our Site via a browser on your mobile device, we may collect mobile network information including telephone number, the unique device identifier assigned to your device, mobile carrier, operating system, and other device attributes.
Cookies and Other Tracking Technologies
Like many sites, we use “cookies” to collect information. Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.
- Session Cookies: We use session cookies to make it easier for you to navigate our Site. A session ID cookie expires when you close your browser.
- Persistent Cookies: We use persistent cookies that remain on your hard drive for an extended period of time. For example, we may set a persistent cookie to store your password, so you don’t have to enter it more than once.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
We may also use other website or mobile tracking technologies to identify you and keep track of your preferences, prevent fraudulent activity or improve Site security, and assess the performance of the Site.
The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services.
One of the third-party services that we use is Google Analytics, which is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of our Site and may share this data with other Google services. You can learn more about how Google uses and shares Personal Information and about any choices you may have with regards to your Personal Information by visiting their website at www.google.com/policies/privacy/partners/.
We may also use Remarketing with Google Analytics to advertise online. Third parties, including Google, may show ads on websites across the internet. This Site and third parties, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to our Site and report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to this Site.
You can understand which third parties have currently enabled cookies for your browser or mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative's website at http://optout.networkadvertising.org/#!/; or the Digital Advertising Alliance's website at http://optout.aboutads.info/#!/ from your browser. For more information on mobile specific opt-out choices, please visit http://www.networkadvertising.org/mobile-choices.
Statistical or aggregated information does not directly identify you or any specific person, but it may be derived from your Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users in a particular ZIP code.
How We Use and Share Information
We use Personal Information that we collect in the following ways:
- Provide Services: We use your Personal Information in order to provide you with our services and to fulfill our contractual obligations to you.
- Communicate: We use Personal Information to communicate with you about our Site or services. We may also use your Personal Information to send you account updates or other communications regarding your account or to inform you of any changes to our Site or services.
- Marketing: We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information. All marketing and promotional communications (such as email newsletters and text alerts) require you to opt-in to receive such communications and will provide an opt-out method as described within the communications channel.
- Specific Purposes: You may be asked to provide information for a specific purpose. For example, we may request that you fill out a survey to provide us with feedback on our technical support. We will only use the information that you provide for the purpose for which you provided it to us or for other purposes.
- Customer Support: We may use your Personal Information to provide you support or other services you request. For example, we may need your information in order to provide technical support or answer questions about our Site.
- Maintenance and Improvement: We analyze how our users interact with our Site in order to maintain and improve it. We also use information that we collect to diagnose any problems with our Site to improve the user experience.
We reserve the right to share information, including Personal Information, with third parties, as described below:
- Service Providers: We may share information with service providers that help us perform Site functions and administer our services. For example, we may share your information with third-party customer service providers.
- Corporate Family: We may share information within our corporate family, such as with subsidiaries, joint ventures, or affiliates, to the extent permitted by law.
- Corporate Structure: We may share information in connection with a merger, acquisition, consolidation, change of control, or sale of all or a portion of our assets or if we undergo bankruptcy or liquidation.
- To Prevent Harm: We may share information if we believe it is necessary in order to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.
- For Legal Purposes: We will share information where we are legally required to do so, such as in response to requests from our regulator, other Farm Credit associations for purposes allowed by law, court orders or legal process, to establish, protect, or exercise our legal rights, to defend against legal claims or demands, or to comply with the requirements of any mandatory applicable law.
- With Others under Duty of Confidentiality: We may share information with others for the purpose of conducting business when the other party is under a contractual duty of confidentiality.
- With Your Consent: We may request your permission to share your Personal Information for a specific purpose. We will notify you and request consent before you provide the Personal Information or before the Personal Information you have already provided is shared for such purpose.
Since 1972, Farm Credit Administration (“FCA”) regulations have generally restricted the disclosure of most types of Personal Information and other information provided to us while applying for or obtaining a loan (“Personal Borrower Information”). Specifically, employees and the director of a Farm Credit institution may not disclose the Personal Information of their borrowers to others without your consent in certain circumstances. We may disclose your Personal Borrower Information and other Personal Information to our employees, contractors, agents, affiliates, third-party service providers, independent auditors, regulators, consultants or attorneys, or to any third-party if otherwise permitted by the FCA regulations applicable to us, such as 12 C.F.R. Part 618, Subpart G, or as otherwise required or permitted by law.
We are committed to the security of your Personal Information. We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your Personal Information. However, because the Internet is not a 100% secure environment, we cannot guarantee, ensure or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails and other communications you send to us through the Site may not be encrypted, and we strongly advise you not to communicate any Personal Information through these means. We will never ask you to update, validate or in any other way request Personal Information via non-secured email or other non-secured channels.
Children’s Online Privacy Protection Act
We do not knowingly collect, use or maintain any information through the Site about children who are under the age of 13 years. If we determine that a child under the age of 13 years has provided us with information through the Site, we will only use this information to notify the parents that this information was received and such information will be deleted. If you believe we might have any information from a child under the age of 13 years, you may contact us at [email protected] or by calling 844-426-6733.
Links to Third-Party Websites
The Site may contain links to third-party websites that are not owned or controlled by us. While we may provide links on the Site to other websites of interest we cannot endorse, approve or guarantee the information, products, services or recommendations provided on any third-party website. When you visit a third-party website by using a link from our website, you will no longer be protected by our privacy or security statements and practices. Your use of such linked websites is subject to the terms and conditions and privacy policies of the providers of those websites; therefore we encourage you to familiarize yourself with their privacy and security practices.
Browser Do Not Track
The Site is not currently configured to respond to Do Not Track signals.
Changes to This Privacy Statement
We reserve the right to update or change our Privacy Statement at any time, and you should check this Privacy Statement periodically. Your continued use of the Site after we post any modifications to the Privacy Statement on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Statement.
If you have any questions or would like to make a request regarding this Privacy Statement, please contact us.
Email: [email protected]
2600 Jenny Wren Trail
PO Box 810
Sun Prairie, WI 53590
California-Specific Description of Consumers’ Privacy Rights
We collect personal information in connection with both consumer and commercial clients and prospective clients. The term “consumer” in this Policy shall not be construed to limit the applicability of this Policy to consumer purpose accounts.
Right to Know
A consumer has the right to request the following:
- The categories of personal information we have collected about that consumer.
- The categories of sources from which the personal information is collected.
- Our business or commercial purpose for collecting or selling personal information.
- The categories of third parties with whom we share personal information.
- The specific pieces of personal information we have collected about that consumer.
A consumer has the right to request that a business that sells the consumer’s personal information, or that discloses it for a business purpose, disclose to that consumer:
- The categories of personal information sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
- The categories of personal information disclosed about the consumer for a business purpose.
Right to Delete
A consumer has the right to request the deletion of their personal information collected by us.
We may deny a consumer’s request to delete in order to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of our ongoing business relationship with the consumer, or otherwise perform a contract between us and the consumer.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- Comply with the applicable provision of the California Electronic Communications Privacy Act.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
- Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with us.
- Comply with a legal obligation.
- Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
Right to Opt-Out
A consumer has the right, at any time, to opt-out of the sale of their personal information.
Right to Non-Discrimination
Finally, we will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under CCPA, including, but not limited to, by:
- Denying goods or services to the consumer.
- Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
- Providing a different level or quality of goods or services to the consumer.
- Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.
Categories of Personal Information Collected or Disclosed
We have collected or may have disclosed the following categories of personal information about consumers for a business or commercial purpose in the preceding 12 months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||Yes||Yes|
|B. Personal information categories described in Cal. Civ. Code § 1798.80(e).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||Yes||Yes|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||Yes||Yes|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes||Yes|
|E. Biometric information.||Genetic, psychological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, and voiceprints, oros or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No||No|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||Yes||Yes|
|G. Geolocation data.||Physical location or movements.||Yes||No|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information||Yes||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||Yes||Yes|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||Yes||No|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes||Yes|
Sources of Personal Information
We collect personal information about consumers from:
- Consumers directly.
- Credit reporting agencies.
- Financial institutions.
- Government sources from which public records are maintained.
- Legal entities established pursuant to the Farm Credit Act of 1971, as amended.
- Our business partners.
- Service providers with whom we have a contractual relationship.
Personal Information Collection Purposes
We collect personal information directly from consumers in order to provide them with loans and other products or services within the scope of its charter as an association of the Farm Credit System. This requires us to verify the identity of our clients and determine their ability to borrow for which we collect identifying information and financial information. For example, it is Compeer’s policy to obtain a current copy of our borrowers’ government-issued identification, such as a driver’s license. We also collect tax identification numbers to uniquely identify our clients. Additionally, Compeer collects balance sheets from our clients through our secure portal or by mail.
Similarly, we collect personal information from credit reporting agencies in contemplation of the extension of credit, administration of credit, or the collection of loans. This may include a loan applicant’s income and payment history, debts, and other financial information to assess the applicant’s capacity to repay debts.
We also collect personal information about consumers from financial institutions and legal entities established pursuant to the Farm Credit Act of 1971, as amended, that we partner with to provide financial services to consumers.
When a client signs documents electronically with Compeer, our electronic signature platform automatically collects data to verify the location of a signer. Additionally, when a client closes a loan or other transaction using our remote online notarization service, we are required to maintain a recording of the audio-video session for a period determined by state law.
Finally, we collect personal information, including employment-related information, from our employees and job applicants for human resources purposes.
Personal Information Disclosed
We may disclose personal information for business or commercial purposes. It is our policy not to disclose or make available any personal information or other sensitive information unless we have entered into a contract with the party receiving the information to keep such information confidential and not to use it for any purpose except as described in the contract or as otherwise agreed to or directed by the consumer.
We disclose personal information for business purposes to the following categories of third parties:
- Credit reporting agencies.
- Financial institutions.
- Legal entities established pursuant to the Farm Credit Act of 1971, as amended.
- Our business partners.
- Service providers with whom we partner to offer products and services.
Categories of Personal Information Sold
We have not sold personal information in the preceding 12 months.
Designated Methods for Submitting a Request
Personal information requests may be made by using this webform, emailing [email protected], or by calling us at 844-426-6733.
Consumers making personal information requests by phone or email should clearly communicate their specific request (i.e. request to know categories of personal information collected; request to know specific pieces of personal information collected; request to delete personal information; to opt-out) and provide the consumer’s full name, residential address, email address, and telephone number. We will only use information provided by a consumer making a CCPA-related request for the specific purpose of handling consumer inquiries about our privacy practices or ensuring our compliance with CCPA.
All employees responsible for handling consumer inquiries about our privacy practices or our compliance with CCPA are informed of all applicable statutory requirements and how to direct consumers to exercise their rights under the law.
Requests Submitted by Authorized Agents
When a consumer uses an authorized agent to submit a request to know or a request to delete, we will require the consumer to directly confirm that they provided the authorized agent permission to submit the request by requiring a copy of the written and signed permission given by the consumer to the authorized agent. We will also require the consumer to verify their own identity directly with us. In accordance with FCA regulations (12 C.F.R. Part 618, Subpart G) and CCPA § 1798.196, we may only provide personal information directly to a consumer if that consumer is a borrower for purposes of Farm Credit Administration regulations, regardless if the request was submitted by an authorized agent on behalf of such borrower.