Privacy Statement

Spectrum Credit Union's privacy policy, adopted early in 2001, protects the member from exposure of their private information. Mailings are handled directly by our statement mailhouse, ensuring the confidentiality of member information. Typical mailhouse information is restricted only to name, address and phone number. No social security numbers or credit card numbers are included as part of mailhouse information.

Within Spectrum, we limit our own employees' contact with member information to those whose job it is to process that information. For example, member loan information is contained only within the loan department. Spectrum's commitment is to NEVER knowingly allow members' private information to be at risk and out of control of the confidentiality and security of the credit union. At Spectrum FCU, we selectively share information only in conjunction with the legal operation of credit union business and only as allowable by law and policy.

Please read the privacy disclosure. It helps private information remain private.

MEMBER PRIVACY NOTICE DISCLOSURE

The directors, management and staff of Spectrum Credit Union are concerned about and respect the privacy of our members' personal 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 information.

Spectrum 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 Section 716 of NCUA Rules and Regulations.

Types of Information the Credit Union Collects

At Spectrum Credit Union, we collect nonpublic personal information from many sources.

Examples include:

• Your applications for our products and services
• Merchants and other financial institutions through whom you request processing of credit union transactions, such as ATM or debit card transactions
• Consumer reporting agencies
• Third parties who verify information you have supplied on your applications for our products or services, such as employers and other creditors.

Nonpublic personal information means information that we obtain because you have requested financial products or services from us, and may include, for example, your name, your address, your phone number, your assets and your income. Nonpublic personal information does not include information the Credit Union obtains from government records, widely distributed media, or government-mandated disclosures.

Types of Information the Credit Union Discloses

We disclose nonpublic personal information about our members only as required or permitted by law. Because of the way in which we limit our disclosure of nonpublic personal information about you, our disclosure of information about you is not subject to opt-out rights that you may have heard about.

We may disclose any nonpublic personal information we have about you consistent with this policy.

Types of Third Parties to Whom the Credit Union Discloses Nonpublic Personal Information

We can disclose information about you as necessary to conduct our business, to process our transactions, and to comply with legal requirements.

Examples of third parties to whom we can disclose information about you and circumstances under which we can disclose information about you for these reasons include but are not limited to:

• Other financial institutions and entities such as the Federal Reserve who are involved in processing your transactions
• Consumer reporting agencies
• Our auditors, government examiners, attorneys and accountants
• Other creditors who legitimately inquire about our credit experience with you
• Persons to whom you have given us permission to disclose information
• Unaffiliated third parties we have contracted with to provide credit union products or services to you, such as on-line banking and bill payment vendors, plastic card issuers, statement printers and mail houses
• When we receive a validly issued subpoena, government information request, or other valid legal process
• When necessary to protect the security of our records

Safeguarding Member Information

• At Spectrum Credit Union, we protect member privacy by ensuring that only employees who have a business reason for knowing information have access to it. The Credit Union has appointed a Financial Privacy Coordinator, who is responsible for maintaining internal procedures to ensure that our member's information is protected. For example, information in loan files can only be accessed by employees who work in the loan origination or loan operations department.
• All employees have a copy of this disclosure and the Credit Union's Member Financial Records Privacy Policy and are trained at least annually regarding the importance of safeguarding member information. The Financial Privacy Coordinator, the Human Resource Manager and the appropriate department managers will take disciplinary action against any employee who violates the Credit Union's privacy policy and procedures.
• 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 period of time to opt out of the disclosure, if appropriate. Our physical, procedural and electronic safeguards meet standards established by Federal law.