Privacy Statement
Table of Contents
Information Collection
Use of Cookies
How We Use Information
How We Share Information
Borrower Privacy Under the Farm Credit Act
Security and Intrusion Detection
Children’s Online Privacy Protection Act
Notice to International Users
Browser “Do Not Track” Signals
Links to Third-Party Websites
Data Retention
Changes to This Privacy Statement
Contact Us
Overview
This Privacy Statement applies to:
- Farm Credit East, ACA, and our subsidiaries, including Farm Credit East, FLCA and Farm Credit East, PCA (“FCE”, “us”, “we” or “our”);
- FCE’s online properties, including our websites (www.farmcrediteast.com and www.countrylivingloans.com), websites or mobile applications that link to our websites, our social media pages or handles, and any other online or hosted services or software platforms (collectively, our “Digital Platforms”); and
- FCE’s products and services (collectively, the “Services”).
Protecting your privacy is important to us, and this Privacy Statement details how FCE collects, uses, protects, and/or discloses your personal information.
As a member of the Farm Credit System, we are subject to the confidentiality regulations of the Farm Credit Administration along with various states’ data privacy laws. We are committed to protecting the information we collect with the same care that we use in all customer and prospective customer interactions within FCE.
FCE has implemented policies, procedures, and internal controls to protect your personal information. We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. Our employees, directors, and agents are informed of their responsibility to protect your personal information and are governed by standards of conduct and other policies which prohibit the unauthorized use of your personal information.
Because the Internet is not a secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us via standard email. Because of this, we ask that you avoid communicating any sensitive or confidential personal information (such as your social security number) through unsecure or unencrypted channels.
Information Collection
We collect information about you in a variety of ways depending on how you interact with us and our Digital Platforms and Services. The information we collect helps us identify and contact you, carry out certain business purposes further described below, and provide Services to our customers and potential customers. For example, we may collect personal information about you when you use our client portal, make a payment, or contact us.
Information You Provide
We may collect information that you provide to us through our Digital Platforms and/or in connection with our Services, including when you submit applications for our Services, submit inquiries related to our Services, become a customer and transact with us, and/or communicate with FCE team members in person, over the phone, via email, or via other methods.
Such information may include, but is not limited to, contact and professional information (e.g., name, address, e-mail address, phone number), demographic information, financial account information (e.g., bank statements, income tax returns, other loan account information, schedules of assets and liabilities, proof of income), information to facilitate identity authentication practices (e.g., biometric and/or geolocation information), payment information, content you may include in survey responses, information you make available to us via social media platforms, information contained in your communications to us, any information or data you provide by interacting in our online forums or by commenting on content posted regarding our Services, information typically collected in consideration of lending products and services (e.g., government issued identification, social security number or tax identification number, date of birth, marital status, education records, and employment information and history), website usage and technical information, and any other information you submit to us. If you choose to send us a contact request, chat, or other communication with information about yourself, we may maintain records of your correspondence.
We use this type of information to respond to your request(s), provide our Services, operate and improve our Digital Platforms, and share information promoting our Services. We do not sell this information to people or organizations outside FCE.
Information Provided by Third Parties
We may receive certain personal information about you from other people or organizations. We may combine this information with the personal and other information we have collected about you under this Privacy Policy. For example, we may receive information about your credit history from a credit reporting agency or income information from your employer. Please note that if you choose to apply for a loan online, you are authorizing us to obtain credit history information needed to make lending-related decisions.
FCE’s third-party risk management practices require that third-party vendors undergo a formal vetting process before onboarding, which may include review of the vendor’s security certifications (e.g., ISO 27001, SOC 2), privacy policies, and relevant compliance audit reports. Every effort is made to ensure that vendors are contractually obligated to implement strong technical and organizational safeguards (e.g., encryption, access controls, incident notification, audit rights, and the ability to terminate relationships in response to security or privacy breaches).
Device and Usage Information
We may collect information through your use of our Digital Platforms. FCE primarily uses this information to make our Digital Platforms and Services more useful to visitors and customers, to learn about the number of Digital Platform visitors, and to learn about the types of technology our visitors and customers use. For example:
- Transactions or Communications: We may collect information regarding account access, chats, payments and transactions, applications, and underwriting.
- Usage Information: We may collect certain information such as which of our website pages you access, the time and date of access, and the frequency of access.
- Location Information: We may collect information about your physical location. We may use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points, and cell towers.
- Device Information: We may collect information about the device you are using, such as hardware model, operating system, application version number, browser type and version, and IP addresses.
- Online Advertisements: We may use third-party tools to inform, optimize, and/or serve ads based on each visit to our websites and analyze interactions with these ad services.
- Mobile Device Information: When you access our Digital Platforms via a browser on your mobile device, we may collect mobile network information including telephone number, the unique device identifier assigned to your device, mobile carrier, operating system, and other device attributes.
- Social Media Information: Our Digital Platforms may also include social media features, such as the Facebook “Like” button, and other widgets such as the “Share” button provided by third parties. These third parties may provide cookies or other tracking technologies to collect information about you when you use our Digital Platforms.
Use of Cookies
A cookie is a small data file that many websites write to your hard drive for record-keeping purposes when you visit them. For the avoidance of doubt, like many websites, we may use cookies and other tracking technologies for various purposes such as storing information if you are registered with our Digital Platforms, better understanding of the interests of our customers and our Digital Platform visitors, fraud prevention, and monitoring our marketing campaigns. The information collected may be associated with your personal information and/or data about your online activities over time and across different websites and other online services.
For example, if you log-in to our Digital Platforms via an Internet web browser and select “remember me”, a cookie is created on your computer with your username and password in an encrypted format , allowing the browser to log you in automatically the next time you visit. Another example of a session cookie stored is zip code information that you may enter when checking weather-related information on this website.
You can set your browser to refuse cookies or to alert you when one is being sent. Because settings vary by device and browser, check your device settings or browser help menu for instructions. Please note that you will need to manage your cookie settings for each device and browser that you use. However, if you block cookies, some features of our Digital Platforms that make your user experience may not be available.
Occasionally, you may encounter banner advertisements for our Services on third-party websites and/or mobile applications. We use third-party advertising service providers to distribute our advertisements on websites and mobile applications where we have paid to advertise. These advertisements may use tracking technologies to capture information such as IP address, browser type, and usage information in order to evaluate the performance of our marketing initiatives. We may associate the information collected by these technologies with your identity. Our advertising service providers may only use information collected to track advertising effectiveness.
In addition, we use advertising service providers to place advertisements for our Services on websites not affiliated with us, and to help us determine which of our advertisements are most likely to be of interest to you using non-personal behavioral information. Advertisements placed by these service providers may use tracking technologies that allow monitoring of your responsiveness to such advertisements. The purpose of collecting this information is similarly limited to assisting us with our advertising efforts.
How We Use Information
We collect and use personal information only to an extent that is reasonably necessary and proportionate to fulfill the specified purposes set forth below. We may use personal information that we collect in the following ways:
- Applications and Transactions: We may use your personal information to process, underwrite and rate your applications and accounts, or process other transactions.
- Provide Services: We may use your personal information in order to provide our Services to you and to support our core business functions. For example, we may use your personal information to issue proper billing statements, offer you our Services, fulfill our other contractual obligations to you, and/or enforce our rights arising from contracts with you.
- Communication: We may use personal information to communicate with you about our Digital Platforms or Services. We may also use your personal information to send you communications regarding your account or to inform you of any changes to our Digital Platforms or Services.
- Identity Verification: We may use your personal information to verify your identity (such as when you access your account information), prevent fraud, and enhance security.
- Advertising and Marketing: We may use your personal information to send you marketing communications, personalize the advertisements you see on our Services and third-party websites, and measure the effectiveness of our advertising. Where permitted by law, we may share your information with business partners, online advertising partners, and social media platforms for this purpose.
- Analysis: We may use information we know about you to analyze our business and markets after making reasonable efforts to remove personal information from the data set (i.e., through the use of de-identified data) in order to understand more about our customers, to inform user interest and/or product development, or for other commercial purposes as permitted by law.
- Specific Purposes: You may be asked to provide information for a specific purpose. For example, we may request that you fill out a survey to provide us with feedback on our technical support.
- Customer Support: We may use your personal information to provide you support or enhance your customer experience.
- Maintenance and Improvement: We may analyze how users interact with our Digital Platforms and/or Services in order to maintain and improve them.
- Legal Compliance: We may use your personal information to comply with legal process, such as warrants, subpoenas, court orders, and lawful regulatory or law enforcement requests and to comply with applicable legal requirements.