NOTICE OF YOUR FINANCIAL PRIVACY RIGHTS

This is our privacy notice for our members. When we use the words "you" and "your" we mean all of our consumer members who have a continuing relationship with us through our services, such as:

• Deposit accounts

• Loan accounts

• Credit cards

• Self-directed Individual Retirement Account, with which we act as custodian or trustee

• Home mortgage & brokerage of such

We will inform you of the source for nonpublic personal information (collected on our members) as well as the measures we take to secure that information. We will also tell you what information we share with other entities. We will explain what your rights are, and how you can exercise them. If you share your account relationship with someone else (for example, if you are a co-borrower or joint-signer on any BOND account), we suggest that you share this information with each other to ensure that each of you are aware of our policy and your options. We first define some terms.

We,our, and us mean BOND Community Federal Credit Union.

Nonpublic personal information means information about you that we collect in connection with providing a financial product or service to you. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records.

An affiliate is a company we own or control.

A nonaffiliated third party is a company that is not an affiliate of ours.

Opt out means a choice you can make to prevent certain sharing of information. We will explain how you can exercise this choice.

THE INFORMATION THAT WE COLLECT

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications or other forms

• Information about your transactions with us

• Information about your transactions with nonaffiliated third parties

• Information from a consumer reporting agency

THE CONFIDENTIALITY, SECURITY, AND INTEGRITY OF YOUR NONPUBLIC PERSONAL INFORMATION

We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.

NONPUBLIC PERSONAL INFORMATION AND NONAFFILIATED THIRD PARTIES

We may disclose nonpublic personal information to nonaffiliated third parties. Here are the kinds of nonpublic personal information we disclose to nonaffiliated third parties:

• Nonpublic personal information we receive from you on an application or other forms, such as

• Name

• Address

You may opt-out of the disclosure of the information listed above.

Types of Nonaffiliated Third Parties

We may disclose nonpublic personal information about you to the following types of nonaffiliated third parties:

• Financial service providers, such as insurance agents

• Businesses offering non-financial products or services, such as other cooperative organizations

We may also disclose nonpublic personal information about you to nonaffiliated third parties as permitted by law.

Reasons For Disclosing

Here is why we may disclose nonpublic personal information about you to nonaffiliated third parties:

• To provide our members with information about additional products and services

• To offer benefits to customers

• To offer benefits to members

Limitations on Disclosure

Here are the limitations we impose on the use of nonpublic personal information disclosed to nonaffiliated third parties:

• We do not allow telephone solicitations.

• All sharing is done only through third-party mailing companies; no information is given directly to nonaffiliates.

NONPUBLIC PERSONAL INFORMATION: FORMER MEMBERS

We do not disclose nonpublic personal information about former members.

NONPUBLIC PERSONAL INFORMATION: AFFILIATES & FUTURE CHANGES

In the future, we may disclose nonpublic personal information about you to affiliates, even though we are not doing so now. We may disclose nonpublic personal information to our affiliates related to information regarding transactions and experiences with us per our account records, such as:

• Name(s)

• Address

• Account balance(s)

• Account activity

• Type(s) of account(s)

• Credit card usage

• Payment history

• Deposit history

Federal law allows us to disclose the information listed above with our affiliates. You do not have a right to opt-out of the disclosure of this information.

Other information not taken from transactions and experience:

• Nonpublic personal information we receive from you on an application or other forms, such as

  • Social security number

  • Assets and Income

• Nonpublic personal information we receive from a credit reporting agency, such as

  • Creditworthiness

  • Credit history

You may opt-out of the disclosure of the information listed above.

Types of Affiliates

We may disclose nonpublic personal information about you in the future to the following types of affiliates:

• Financial service providers, such as  Credit Union Service Organization (CUSO)

Reasons For Disclosure

Here is why we may disclose nonpublic personal information about you in the future to our affiliates:

• To provide our members with information about additional products and services

• To evaluate our total relationship with you and our family of companies and give you the best price that relationship deserves

YOU HAVE THE RIGHT TO CHOOSE

In this notice, we have explained our policy about the disclosure of certain information.

Affiliated Parties: We have explained the kinds of nonpublic personal information we may disclose to our affiliates in the future. We have also explained the kinds of affiliates with whom we may disclose the nonpublic personal information. If you prefer that we do not disclose nonpublic personal information to our affiliates you may opt-out of those disclosures, that is, you may direct us not to make those disclosures (other than the disclosures permitted by law). Nonaffiliated Third Parties. We have explained the kinds of nonpublic personal information we may disclose to nonaffiliated third parties. We have also explained the kinds of nonaffiliated third parties with whom we may disclose the nonpublic personal information. If you prefer that we do not disclose nonpublic personal information to nonaffiliated third parties, you may opt-out of those disclosures, that is, you may direct us not to make those disclosures (other than the disclosures permitted by law).

Non-affiliated Third Parties: We have explained the kinds of nonpublic personal information we may disclose to nonaffiliated third parties. We have also explained the kinds of nonaffiliated third parties with whom we may disclose the nonpublic personal information. If you prefer that we do not disclose nonpublic personal information to nonaffiliated third parties, you may opt-out of those disclosures, that is, you may direct us not to make those disclosures (other than the disclosures permitted by law).

Your decision to block the disclosure of your nonpublic personal information will apply to all products and services you receive from us.

If you have a joint account, each participant of this account has a separate right to opt-out. If one of you chooses to opt-out of the disclosure of nonpublic personal information and another does not, only information regarding the party who does not opt-out will be disclosed. Any participant on the account can opt-out on behalf of any other participant of the account.

If you wish to opt-out of disclosures, you may do so by requesting a Privacy Statement disclosure form, checking the appropriate box(es) on the included Opt-Out Notice, and returning it to us at this address:

BOND Community Federal Credit Union

PO Box 5286

Atlanta, Georgia 31107

(You may request the form through Member Services: 404-525-0619, ext 219.)

Limitations on Disclosure

Here are the limits we would impose on the use of nonpublic personal information disclosed to affiliates:

• Only mortgage customers will be contacted.

YOUR RIGHT TO BLOCK THE DISCLOSURE OF YOUR NONPUBLIC PERSONAL INFORMATION

Affiliated Parties: We are permitted to disclose nonpublic personal information about our transactions or experience with you to affiliates in the future. We may also disclose other nonpublic personal information to our affiliates (that is, nonpublic personal information beyond our transactions and experiences with you), unless you tell us to not disclose this other nonpublic personal information.

Nonaffiliated Third Parties: If you do not want us to share your nonpublic personal information with non-affiliated third parties, you can block the release of certain nonpublic personal information. This is known as your right to "opt-out."

Your decision to block the disclosure of your nonpublic personal information will apply to all products and services you receive from us.

If you have a joint account, each participant of this account has a separate right to opt-out. If one of you chooses to opt-out of the disclosure of nonpublic personal information and another does not, only information regarding the party who does not opt-out will be disclosed. Any participant on the account can opt-out on behalf of any other participant of the account.

If you wish to opt-out of disclosures, you may do so by requesting a Privacy Statement disclosure form, checking the appropriate box(es) on the included Opt-Out Notice, and returning it to us at this address:

BOND Community Federal Credit Union

PO Box 5286

Atlanta, Georgia 31107

(You may request the form through Member Services: 404-525-0619, ext 219.)

As a Community Development Financial Institution, BOND Community Federal Credit Union does not exclude, deny benefits to, or otherwise discriminate against any person on the grounds of race, color, national origin, disability, age, sex, gender identity, religion, or creed in employment or receipt of the services and benefits under any of its programs and activities. BOND CFCU provides equal access to its members and potential members.

The following person has been designated to handle BOND Community Federal Credit Unions non-discrimination inquiries:

BOND Community Federal Credit Union

Attention: Linda Lopez, Chief Operations Officer

P.O. Box 5286

Atlanta, GA 31107

404-525-0619 ext. 218

linda@bondcu.com

Any person eligible to receive benefits or services from the Department of Treasury – Community Development Financial Institutions (CDFI Fund) or its recipients is entitled to those benefits or services without being subject to prohibited discrimination. The Office of Civil Rights and Equal Employment Opportunity (OCRE) enforces various federal statutes and regulations that prohibit discrimination in CDFI Fund financially assisted and conducted programs or activities. If a person believes s/he has been subjected to discrimination and/or reprisal because of membership in a protected group then s/he may file a complaint with: Director, Office of Civil Rights and Equal Employment Opportunity, 1500 Pennsylvania Ave, N.W., Washington, DC 20220 or crcomplaints@treasury.gov.

Upon request, a Spanish translation of the Nondiscrimination and Civil Rights Information web page is available at the Community Development Financial Institutions Fund: Non-Discrimination Statement and Civil Rights Information.

Para solicitar esta información en español, envíe una solicitud a través de cdfihelp@cdfi.treas.gov.

To request this information in Spanish, please submit a request to cdfihelp@cdfi.treas.gov.

To file a discrimination complaint related to our CDFI Fund program with the Department of the Treasury Office of Civil Rights and Equal Employment Opportunity, write to:

U.S. Department of the Treasury, Director,

Office of Civil Rights and Equal Employment Opportunity

1500 Pennsylvania Avenue, N.W.,

Washington, DC 20220;

or send an email to:  crcomplaints@treasury.gov.

1. OVERVIEW

 In compliance with Title VI of the Civil Rights Act of 1964 and Executive Order 13166, "Improving Access to Services for Persons with Limited English Proficiency", BOND Community Federal Credit Union has established the following LAP to ensure that individuals with limited English proficiency (LEP) may access all resources and services provided by our credit union. According to Executive Order 13166, an "LEP individual" is defined as "an individual who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English."  With Spanish being the second most spoken language in field of membership and the state of Georgia at large, this language assistance plan includes a specific emphasis on the Spanish-speaking community.

 2. PURPOSE

 The purpose of this Language Access Plan is to make reasonable efforts to eliminate or reduce English proficiency as a barrier to accessing BOND CFCUs products, services, and programs.

 3. LEP Needs Assessment

 BOND serves members primarily in Fulton and DeKalb Counties, Georgia, where the most common non-English language is Spanish. Based on U.S. Census and member interaction data, Spanish-speaking LEP individuals represent the primary group in need of language assistance.

 4. COMPLIANCE

 The Chief Operations Officer will be responsible for overseeing the implementation of this plan. In addition to their oversight duties, this individual will be charged with maintaining and updating this plan as the need for changes arises. The individual will report to President/CEO and will need to coordinate with President/CEO to carry out the directives established by this plan.

 5. TRAINING

Staff are informed annually of LAP procedures and trained to recognize and assist LEP individuals.

 6. LANGUAGE SERVICES PROVIDED

 1.    LEP individuals may interact with our staff in several ways:

 a)    Branch assistance

b)    Contact Center assistance

c)    Website with Google translation capabilities

d)    Secured Contact Us or Complaints

e)    ATM transactions are offered in English and Spanish

f)     Written materials

g)    Brochures (including bi-lingual)

2.    Oral Language Assistance

a)    Oral language assistance may be needed during interactions with LEP individuals by phone, in person, or at community events.  When such an interaction occurs, staff will follow the protocol outlined below:

•  For communication over the phone:

The staff members will first try to identify the primary language of the individual.  If that staff member is approved by BOND CFCU as bilingual in the individual's primary language, then that staff member may assist the LEP individual directly. If the staff member has not been approved as bilingual in that language, then that staff member will transfer the call to another staff member who has been approved as bilingual. If no bilingual staff member is available to assist the individual, then the LEP may request a call back from a Spanish speaking staff or an interpretation tool such as Google Translate may be used to communicate with the LEP individual. 

• For communication in person:

The staff members will first try to identify the primary language of the individual. If that staff member is approved by BOND CFCU as bilingual in the individual's primary language, then that staff member may assist the LEP individual directly. If the staff member has not been approved as bilingual in that language, then that staff member will contact another staff member who has been approved as bilingual in the LEP’s language to come and assist the individual. If no bilingual staff member is available to assist the individual, then the LEP may request a call back from a Spanish speaking staff or an interpretation tool such as Google Translate may be used to communicate with the LEP individual.

 3.    For communication on our website:

Currently a user can convert our website content into Spanish.

4.    For Community Outreach:

An approved interpreter may be assigned based on language demographic at community events.

5.    Written Language Assistance

a)    Written language assistance may be needed for several documents, notices, advertisements, forms, etc.

b)    "Vital documents" will be translated proactively and made accessible to the LEP communities previously identified. Documents will be classified as “vital” by balancing the frequency of contact that LEP individuals have with the document.  The importance and potential consequences associated with the document, and organizational resources. Anecdotal evidence and data will be used to support these classifications, as it becomes available.

c)    Documents not considered vital will be available for oral or written translation upon request.

d)    Translated documents will also be accompanied by the following disclaimer:

 "We are providing the translation to you merely as a convenience to assist in your understanding of your rights and obligations. The English language version of this document is the official, legal, controlling document. This translated document is not an official document."

 5. GUIDELINES FOR INTERPRETERS AND TRANSLATORS

a)    While no formal certification is required for interpreters, translators, or staff members listed as bilingual, individuals providing interpretation or translation services must:

•  Be proficient in and able to communicate information accurately in both English and other applicable language,

•   Act in an ethical manner and ensure confidentiality and impartiality in their role as an interpreter/translator,

•  Be able to provide the most appropriate interpretation in a consistent manner. 

b)    LEP individuals may bring another individual to provide interpretation who has not been approved for formal interpretation services by the credit union. During these encounters, staff will:

•  Inform the LEP individual that free language assistance services are provided, 

• Use a formal interpreter instead of the informal interpreter, especially if the subject matter of the encounter may be prone to conflicts of interest, contracts or other legal matters, 

• Avoid the use of minors as informal interpreters unless there is an extreme and immediate need. 

c)    When working with an interpreter, formal or informal, credit union staff should:

• Explain to the interpreter the purpose of the communication and the information to be conveyed, 

• Briefly explain to the interpreter technical terms that may come up during the communication, 

• Avoid the use of acronyms, double negatives, and contractions, 

• Speak in short sentences that contain one idea at a time, 

• Talk to the applicant and not to the interpreter, 

• Enunciate clearly and wait for the interpreter to finish before continuing to the next idea.

 6. COMPLAINT PROCESS

 LEP individuals may submit complaints regarding language access to: 

BOND Community Federal Credit Union

Attention: Linda Lopez, Chief Operations Officer

P.O. Box 5286

Atlanta, GA 31107

404-525-0619 ext. 218

linda@bondcu.com