Mobile Banking Privacy Statement

Gain Federal Credit Union – Mobile Banking Privacy Supplement

Effective date: 5/2/2025

This Mobile Banking Privacy Supplement (“Supplement”) describes how Gain Federal Credit Union (“we”, “us”, or “our”) collects, uses, and protects personal information through our mobile banking application (“App”). This Supplement applies only to the App and supplements our full Privacy Policy.

1. How We Use Your Information

We collect and process information through our App to:

• Provide you with mobile banking services and account access;
• Maintain, troubleshoot, and improve our App’s functionality and security;
• Personalize your experience within the App;
• Detect, prevent, and investigate fraud or other unauthorized activities;
• Fulfill legal and regulatory obligations;
• Support features such as mobile check deposit, branch/ATM locators, and P2P payments.

We do not sell or share your personal information for marketing or advertising purposes.

2. Information You Provide

When you register for or use our App, you may be asked to provide:

• Name, address phone number, email;
• Login credentials (e.g., username, password)
• Social Security number, driver’s license, or other ID for identity verification;
• Financial account numbers and payment information.

This information is used to authenticate you and enable secure access to your accounts and services.

3. Information We Automatically Collect

The App may automatically collect technical data, including:

• Device identifiers (e.g., device ID, OS version, mobile carrier);
• IP address and network info;
• App usage logs and diagnostic data;
• Crash reports and system performance data.

We use this information to monitor system health, detect fraud, and improve your experience.

4. Activity Tracking

To improve app navigation and identify issues, we track:

• Page views, clicks, and button usage;
• Navigation flows and screens visited;
• Mobile deposit activity, P2P payments, and transaction history.

This activity is logged using analytics tools and securely stored to help us optimize user experience and detect potential security threats.

5. Device Permissions and Sensitive Data

Our App may request access to the following device features;

• Camera – For mobile check deposit
• Contacts – For P2P payment functionality;
• Location (precise/fine) – For branch/ATM locator and security alerts;
• Biometric authentication (e.g., fingerprint or face ID) – To enable secure frictionless log in.

You will be prompted to grant or deny each of these permissions. Without permission, some features may not be available.

6. Use of Third-Party Tools and SDKs

Our App uses secure third-party service providers and software development kits (SDKs) for services such as:

• Mobile deposit (e.g., image capture) ;
• P2P transfers;
• Fraud detection ;
• Application performance analytics.

These providers are contractually bound to use your information only for these functions and in accordance with this Supplement and applicable law.

7. Sharing your Information

We may share your information with:

• Vendors or service providers assisting with secure app functionality;
• Fraud prevention and cybersecurity partners;
• Legal or regulatory authorities, if required;
• As part of a merger, acquisition, or reorganization with proper notice.

We will never publicly disclose or sell your sensitive personal data.

8. Security Practices

We use encryption, firewalls, and other technical safeguards to protect your information. All transmissions are encrypted using industry-standard protocols.

9. Legal Compliance (GLBA & CPRA)

As a federally insured credit union, we comply with Gramm-Leach-Bliley Act (GLBA) and NCUA regulations concerning financial privacy. While many provisions of the California Consumer Privacy Act (CCPA/CPRA) do not apply to us, we are committed to transparency in how we collect and use your data.

10. Contact Us

If you have any questions about this Mobile Banking Privacy Supplement, contact us.