Privacy Statement
As more financial institutions unveil their Web Sites and launch on-line services, it becomes more difficult to differentiate our credit union from the rest. Our goal is to distinguish our on-line services by going the extra mile to protect our member’s financial privacy.

As reports of identity theft become more common, we have an opportunity to reassure our members that we take financial privacy very seriously. (Please refer to our privacy policy).

Our privacy policy posted on our web site includes:

• The type of information we will gather and what we will use it for;
• What we won’t do with the information;
• A statement about out concern for privacy rights in general and a more specific statement about our respect for members’ financial privacy;
• An explanation of why we gather the information and how gathering it enhances our ability to serve members better, and;
• A reservation of rights to change our policy.

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Privacy Notice Disclosure to Members 12 CFR § 716
The directors, management, and staff of Berks Community Federal 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 and financial affairs.

The credit union will take all the necessary steps to safeguard sensitive information that has been entrusted to us by our members. The following information outlines this credit union's practices regarding personally identifiable financial information for members and others with whom we establish a "member relationship" pursuant to 12 CFR §716 of the National Credit Union Administration's Rules and Regulations.

Types of Information the Credit Union Collects
At Berks Community 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 and forms. For example, loan 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 government records, widely distributed media, or government mandated disclosures.

Types of Information the Credit Union Discloses
The Berks Community Federal Credit Union may disclose the following types of information about current or former members to our affiliates:

Identification information, such as name, address and telephone number;
Transactional Information, and;
Deposit or loan account experience.
Example of the types of businesses we are affiliated with are listed below:

MICRODYNAMICS Distribution mail center for monthly and quarterly
1400 Shore Road statements
Naperville, Il 60563

RTC Local Mail Distribution Center for mass marketing
56 Seip Lane mailings
Shoemakersville, PA 19555

Precision Forms & Graphics Distribution Center that prints and mails notices
258 Wilmington Pike for Enterprise Car Sales
Chadds Ford, PA 19317

Peripheral Systems, Inc. Microfilm
Bertolet Mill Road
Oley, PA 19547

Safeguarding Member Information
At Berks Community Federal 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 Team, who is responsible for maintaining internal procedures to ensure that our members' 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 policy 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 Team and appropriate other staff members will take disciplinary action against any employee who violates the credit union's privacy policy and procedures.

If the policy or practice changes, 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.

Members' Right to Opt Out of Sharing Agreements

Members have the right to opt out of the credit union's sharing agreements with certain affiliates and non-affiliates by completing the "OPT OUT Form" and returning it to the credit union in an acceptable manner described on the form.

If a member signs the opt-out notice at the time an account is opened or application processed, the credit union will honor the request immediately.

However, members may opt out of the information sharing agreements at any time. If a member notifies the credit union after an account is opened or application processed, the credit union agrees to stop sharing the member's information within 30 days from the date the member's request is received.

Exceptions to a Member's Opt-Out Rights

By law, Berks Community Federal Credit Union may share personal information about members without allowing the opportunity to opt out in the following circumstances:

With companies that perform transaction processing for the credit union.

If the transaction, service, or product is requested or authorized by the member;
To maintain or service a member's account as part of a private label credit card or other loan extension program;
In connection with a securization, secondary market (including service rights), or similar transaction related to a consumer.

For disclosures that are necessary to enforce the credit union's legal or contractual rights or the rights of any other person who is engaged in the financial transaction.

For disclosures required in the ordinary course of our business, such as in the settlement of claims or benefits, the confirmation of information to a member or their agent, and the billing, processing, or clearing of items in the normal course of business.

To provide information to insurance rate advisory organizations, guaranty funds or agencies, agencies that are rating the credit union, persons that are assessing the credit union within industry standards, and the credit union's attorney, accountants, and auditors.

To the extent permissible under the Right to Financial Privacy Act (RFPA). See the credit union's policies for guidance on compliance with the RFPA.

To a consumer reporting agency under the Fair Credit Reporting Act.

To comply with federal, state, or local laws, rules and other applicable legal requirements. See the credit union's policies for guidance on compliance with these exceptions.

Berks Community Federal Credit Union may also disclose personally identifiable information to non-affiliated third parties we engage to market our own services or products to members. The credit union will not provide member's personal information to non-credit union companies for the purpose of their independent telemarketing or direct mail marketing of any non-financial products or services.

If the credit union shares information with a third party, non-affiliated marketing firm for the purpose of telling our members about our new products or services, the credit union will enter into a written agreement with the third party that will require that party to maintain confidentiality of the information in the same manner the credit union would and restrict its use.

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Children’s Online Privacy Act (COPPA)
The Children’s Online Privacy Protection Act (COPPA) was signed into law on October 21, 1998. COPPA prohibits unfair or deceptive acts or practices in connection with the collection, use, or disclosure of personally identifiable information from and about children on the Internet. The Federal Trade Commission (FTC) issued the enclosed final rule, 16 CFR Part 312, effective April 21, 2000.

COPPA and the FTC’s implementing rule generally apply to financial institutions that operate commercial websites or provide online services (or portions thereof) directed to, or knowingly collect personal information from children under the age of 13.

COPPA and the FTC’s rule require those financial institutions to:

• Provide parents notice of their information practices;
• Obtain prior verifiable parental consent for the collection, use, and/or disclosure of personal information from children (with certain limited exceptions for the collection of “online contract information, “e.g., an e-mail address);
• Provide a parent, upon request, with the means to review the personal information collected from his/her child;
• Provide a parent with the opportunity to prevent the further use of personal information that has already been collected, or the future collection of personal information from that child;
• Limit collection of personal information for a child’s online participation in a game, prize, offer, or other activity to information that is reasonably necessary for the activity; and
• Establish and maintain reasonable procedures to protect the confidentiality, security, and integrity of the personal information collected.
• At this time, Berks Community Federal Credit Union falls under the exceptions category of the November, 1999 How to Comply with The Children’s Online Privacy Protection Rule.

The regulations include several exceptions that allow operators to collect a child’s e-mail address without getting the parents consent in advance. These exceptions cover many popular online activities for kids, including contests, online newsletters, homework help and electronic postcards.

Prior parental consent is not required when:

• An operator collects a child’s or parent’s e-mail address to provide notice and seek consent;
• An operator collects an e-mail address to respond more than once to a specific request – say, for a subscription to a newsletter. In this case, the operator must notify the parent that it is communicating regularly with the child and give the parent the opportunity to stop the communication before sending or delivering a second communication to a child;
• An operator collects a child’s name or online contact information to protect the safety of a child who is participating on the site. In this case, the operator must notify the parent and give him or her the opportunity to prevent further use of the information;
• An operator collects a child’s name or online contact information to protect the security or liability of the site or to respond to law enforcement, if necessary, and does not use it for any other purpose.

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Legal Disclaimer
Berks Community Federal Credit Union maintains this site (the "Site") for your personal entertainment, information, education, and communication. Please feel free to browse the Site. You may download material displayed on the Site for noncommercial, personal use only, provided you also retain all copyright and other proprietary notices contained on the materials. You may not, however, distribute, modify, transmit, reuse, report, or use the contents of the Site for public or commercial purposes, including the text, images, audio, and video without the written permission of Berks Community Federal Credit Union. Your access and use of the Site is also subject to the following terms and conditions ("Terms and Conditions") and all applicable laws. By accessing and browsing the Site, you accept, without limitation or qualification, the Terms and Conditions and acknowledge that any other agreement between you and Berks Community Federal Credit Union, are superseded and of no force or effect.

Terms and Conditions
1. You should assume that everything you see or read on the Site is copyrighted unless otherwise noted and may not be used except as provided in these Terms and Conditions or in the text on the Site without the written permission of Berks Community Federal Credit Union. Berks Community Federal Credit Union, neither warrants nor represents that your use of materials displayed on the Site will not infringe rights of third parties not owned by or affiliated with Berks Community Federal Credit Union. 2. While Berks Community Federal Credit Union, uses reasonable efforts to include accurate and up-to-date information on the Site, Berks Community Federal Credit Union, makes no warranties or representations as to its accuracy. Berks Community Federal Credit Union, assumes no liability or responsibility for any errors or omissions in the content on the Site. 3. Your use and browsing of the Site is at your risk. Neither Berks Community Federal Credit Union, nor any other party involved in creating, producing, or delivering the Site is liable for any direct, incidental, consequential, indirect, or punitive damages arising out of your access to, or use of, the Site. Without limiting the foregoing, everything on the Site is provided to you "AS IS" WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. Please note that some jurisdictions may not allow the exclusion of implied warranties, some of the above exclusions may not apply to you. Check your local laws for any restrictions or limitations regarding the exclusion of implied warranties. Berks Community Federal Credit Union, also assumes no responsibility and shall not be liable for any damages to, or viruses that may infect, your computer equipment or other property on account of your access to, use of, or browsing in the Site or your downloading of any materials, data, text, images, video, or audio from the Site. 4. Any communication or material you transmit to the Site by electronic mail or otherwise, including any data, questions, comments, suggestions, or the like is, and will be treated as, nonconfidential and nonproprietary. Anything you transmit or post may be used by Berks Community Federal Credit Union, or its affiliates for any purpose, including but not limited to reproduction, disclosure, transmission, publication, broadcast, and posting. Furthermore, Berks Community Federal Credit Union, is free to use any ideas, concepts, know-how, or techniques contained in any communication you send to the Site for any purpose whatsoever, including but not limited to developing, manufacturing, and marketing products using such information 5. Images of people or places displayed on the Site are either the property of, or used with permission by, Berks Community Federal Credit Union. The use of these images by you, or anyone else authorized by you, is prohibited unless specifically permitted by these Terms and Conditions or specific permission provided elsewhere on the Site. Any unauthorized use of the images may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes. 6. The trademarks, logos, and service marks (collectively the "Trademarks") displayed on the Site are registered and unregistered Trademarks of Berks Community Federal Credit Union, and others. Nothing contained on the Site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any Trademark displayed on the Site without the written permission of Berks Community Federal Credit Union, or such third party that may own the Trademarks displayed on the Site. Your misuse of the Trademarks displayed on the Site, or any other content on the Site, except as provided in these Term and Conditions, is strictly prohibited. You are also advised that Berks Community Federal Credit Union, will aggressively enforce its intellectual property rights to the fullest extent of the law, including the seeking of criminal prosecution. 7. Berks Community Federal Credit Union, has not reviewed all of the sites linked to the Site and is not responsible for the contents of any off-site pages or any other sites linked to the Site. Your linking to any other off-site pages or other sites is at your own risk. 8. Although Berks Community Federal Credit Union, may from time to time monitor or review discussions, chats, postings, transmissions, bulletin boards, and the like on the Site, Berks Community Federal Credit Union, is under no obligation to do so and assumes no responsibility or liability arising from the content of any such locations nor for any error, defamation, libel, slander, omission, falsehood, obscenity, pornography, profanity, danger, or inaccuracy contained in any information contained within such locations on the Site. You are prohibited from posting or transmitting any unlawful, threatening, libelous, defamatory, obscene, scandalous, inflammatory, pornographic, or profane material or any material that could constitute or encourage conduct that would be considered a criminal offense, give rise to civil liability, or otherwise violate any law. Berks Community Federal Credit Union, will fully cooperate with any law enforcement authorities or court order requesting or directing Berks Community Federal Credit Union, to disclose the identity of anyone posting any such information or materials. 9. Berks Community Federal Credit Union, may at any time revise these Terms and Conditions by updating this posting. You are bound by any such revisions and should therefore periodically visit this page to review the then current Terms and Conditions to which you are bound.

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