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Privacy Policy GENERAL PRIVACY PRINCIPLES First Federal Bank of California does not sell client information to others. We share client information only under certain permitted exceptions. Examples include information given to our data processing services provider in order to process your transaction, or information given to another financial institution solely in order to offer services to you which we do not offer directly, such as credit cards. The following are other general principals we follow to protect your privacy. CLIENT PRIVACY STATEMENT First Federal Bank of California understands that the protection of confidential information is a critical aspect of good client service. Whether you are a long-time client, a new client, or are just considering doing business with us, we want you to know that your nonpublic personal information will be treated with respect for your privacy. This policy covers the limited disclosure of personally identifiable information about our clients. This policy is provided to you as required by the federal financial privacy law regulations. Recognition of our clients’ expectation of privacy We know that your financial information is personal and we are committed to protecting your privacy. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. We will answer any questions you may have about the handling of sensitive information regarding your accounts. Maintenance of accurate client information We have procedures to maintain accurate, current, and complete information about your banking relationship with us, and we correct any inaccuracies promptly. To help us maintain accurate records, please contact our call center, FirstFed Direct, at 888-846-3433 to report any incorrect information regarding your name, address, or account. Limiting employee access to confidential information We maintain policies and procedures to ensure that access to your personally identifiable information is limited to employees with a business reason for knowing such information. We train our employees in the importance of confidentiality and client privacy. Our Code of Conduct emphasizes the importance of keeping this information confidential, and we enforce these employee responsibilities. Protection of confidential information First Federal Bank of California has established security procedures to safeguard your personal and banking information from unauthorized access. We regularly review and test our technology to protect the integrity of our security systems. You can help with this process by regularly reviewing your account and loan statements, and by contacting us immediately if you believe that someone has unauthorized access to your accounts or your financial information.
We collect and disclose client information on a limited basis in accordance with the following practices: Limited collection of client information. We collect only that information which we believe will help us to serve your financial needs. We collect information about you from the following sources: We may disclose the following kinds of information about you to limited categories of parties (who are described in the next section): Information we receive from you on applications or other forms, such as your name, address, social security number, assets and income Information about your transactions with us or others, such as your account balance and payment history Information we receive from a consumer reporting agency, such as your credit worthiness and credit history
Legally permitted disclosures. We may disclose the information that we collect to others on a limited basis. We do not sell or otherwise provide client information to catalogs, direct mail companies, magazines, or other non-financial service providers. Disclosure of nonpublic personal information about our clients or former clients is permitted under some circumstances, such as to selected credit reporting agencies, when it is legally required (such as in response to a subpoena), and to prevent fraud or to comply with a legally permitted inquiry by a government agency or regulator. We also disclose information when authorized by you, to help complete a transaction you initiated. We are permitted to disclose client information to outside service companies who we hire to perform business services for us. We provide only that information necessary to perform the job, and we require them to maintain security and confidentiality of the client information provided. These service companies are not permitted to use any client information for any purpose other than in providing the services we have requested. We also are permitted to provide information to others under joint marketing arrangements. Under these arrangements, we select other companies to provide products and service that we do not offer, such as credit insurance or credit cards. We provide them with only with the limited information necessary to offer these products to you. We are selective in choosing these companies. They are obligated to keep the information we provide to them confidential, and use the information only to provide the services we have requested. Information we share with our affiliates First Federal Bank of California strives to provide a varied array of financial services at a competitive price and with exceptional client service. To assist in that effort, we may from time to time share information among members of our corporate family (our "affiliates") on a confidential basis. This allows us to offer easier access to new or enhanced products, special promotional offers, or other benefits that you might not otherwise know about. You may instruct us not to share information we obtain from others (such as credit reports) among our affiliates, although we may continue to share information about our transactions or experiences with you. Under the Fair Credit Reporting Act, you may tell us that you do not want us to share this non-experience information within the First Fed family of companies by contacting our call center, FirstFed Direct, at 888.846.3433 or by notifying us in writing at: First Federal Bank of California, P.O. 471, Santa Monica, CA 90401, Attn: Banking Operations. Please be aware that we may continue to share transaction and account experience information, as well as other general information, with affiliated companies. Even if you choose to opt out, you will continue to receive statements, statement inserts, and other account information. Please notify us if you believe we have reported inaccurate information about your account to a credit bureau or consumer reporting agency. You should contact us at 888.846.3433 and provide us with your complete name, address, Social Security number, telephone number, account number(s), type(s) of account, specific item of dispute, and the reason why you believe the information reported is inaccurate. Keeping Up-to-Date with our Privacy Policy. We will provide you with notice of our privacy policy annually, as long as you maintain a customer relationship with us. This policy may change from time to time. You can contact us for a current copy at 888.846.3433. Supplemental Online Privacy Guidelines Our Client Privacy Statement explains in general how we protect and, on a limited basis, disclose client information. There is additional information you should know when you visit our website. Categories of personally identifiable information collected on www.firstfedca.com If you simply register to use online banking, we will collect basic information about you, such as name, e-mail address, account number, social security number and zip code. Certain other information about you is also collected that can be used to verify your identity if your log on credentials for the site are forgotten. If you apply for employment using firstfedca.com, additional personal information will be collected. We may also collect information online through cookies, which are pieces of information stored directly on the computer you are using. Cookies can contain a variety of information, such as a simple count of how often you visit a web site or information that allows customization of a web site for your use. First Federal Bank of California uses cookies to display information more effectively to you and to gather data about the usage of our Web site. Any time a cookie is used; personal information is encrypted for our use only and protected from third party access. Protecting Information Online As a current client or as a visitor, any information you provide to us at www.firstfedca.com is protected as described below. Protection of Online Personal Information When you sign up for online banking, you must provide personal information that is necessary in order to process your transactions. To ensure that your information remains confidential, the information is sent to us in a "secure session" established with our data processing services provider. After you submit your online transaction, it is necessary that you end your online session before leaving your computer in order to ensure the privacy of your information. We will keep this online information, and may use it to offer you products and services, as described in this Client Privacy Statement. Handling of E-Mail When you send us an e-mail, we keep your message, your address and our response in order to handle any follow-up questions, as well as to satisfy legal and regulatory requirements. We may, from time to time, contact you at your e-mail address to inform you of products, services and other benefits we offer. You should be aware that regular non-encrypted Internet e-mail is not secure. If we give you a First Federal Bank of California e-mail address, this address is provided for inquiries of a non-sensitive and non-confidential nature. If you conduct online banking and require secure online transmission of information to us, such as specific questions regarding your account, you should use the secure forms for contacting us provided within the online banking pages of our web site. These inquiries will be secure and use encryption. Confidential account information will not be sent to you in an e-mail response. We will contact you by telephone or U.S. mail to provide information we believe should be kept confidential. You may also contact us by telephone, U.S. mail, or by visiting our branches. See the "Branch Location" pages in our web site for additional information. No Information Gathering in Planning Tools The calculators in our site that help you make financial decisions are hypothetical, "what if" scenarios. Examples include the mortgage principal and interest calculator and savings goal calculator. These planners do not capture personal information you may provide. Privacy of Online Banking Your online banking transactions provide information to us and our outside data processing and other service companies. The information may be retained on our system or the system of the outside provider of these services, depending on what is necessary in order to serve you. We use advanced Internet technology to make online banking as secure as possible, such as requiring 128 bit encryption in order to process your transactions. We also require your Social Security number or user identification number and personal identification number (PIN) or password to access your accounts. This information is required in order to establish an online banking service for you. You should maintain your password in strict confidentiality to help ensure the security of your banking information, and remember to close your browser at the end of each session. Encryption When you provide personal information on our web site, the information is encrypted (scrambled) so that it can be read by First Federal Bank of California but not by others. Information Gathering and Retention Some information, such as your e-mail address or account number, is collected and retained by us in order to perform services for you as requested. If you browse our web site without providing that information, personal information such as your e-mail address is not collected. We gather and analyze data regarding usage of our web site, including number of "hits," pages visited, etc., to evaluate the effectiveness of our web site and to improve our services. Access to Web Site by Children The responsibility to protect a child’s identity and privacy is one that is shared by the online provider and the child’s parents. Please be aware that First Federal Bank of California does not intentionally market to children, nor does it intentionally solicit data from children. Caution Against "Spoofers" "Spoofing" is the term used to describe the creation of a close-to-identical image of First Federal Bank of California’s web site in order to lure our clients to the phony site and capture their confidential information. For example, the fraudulent site could be reached by a link containing a slight misspelling of our address (such as flrstfedca.com). You can make sure that you are not a victim of "spoofing" by carefully reviewing the site when you arrive there to ensure that the address does in fact say www.firstfedca.com.
Making Sure Information is Accurate Keeping your account information accurate and up to date is very important. If you want to update this information, please contact FirstFed Direct, at 888-846-3433.ChangesOur Client Privacy Statement may change from time to time. The effective date of this policy, as stated below, indicates the last time this policy was revised or materially changed. Checking the effective date below allows you to determine whether there have been changes since the last time you reviewed the policy. Please check www.firstfedca.com or your local branch office of First Federal Bank of California for the most up-to-date information. Effective Date The effective date of this Client Privacy Statement is July 27, 2006. Thank you for being our client.
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