Cross Creek Privacy Policy


Privacy is an important issue. Please read this Policy to learn how we collect and use information about you.


How do we protect information?
We have standards and procedures to prevent unauthorized access to information. We apply these standards and procedures to our facilities and online services. Our safeguards meet or exceed federal standards for guarding customer information.

We train our employees on the importance of confidentiality and the proper way to handle information. Only those employees with a business reason to access information are authorized to do so. If employees do not follow our standards and procedures, we take appropriate disciplinary action.

What are your options?
You can tell us not to share certain information within the Cross Creek family of companies, with third parties outside Cross Creek Admissions, or both. This is called “opting out” of information sharing. You also may tell us not to solicit you.

How do you exercise your options?
The “YOUR OPTIONS” section at the end of this Policy explains how to opt out of information sharing and limit promotional offers.

What if you already told Cross Creek Admissions your preferences?
You do not need to do anything, your opt out and solicitation decisions stay in effect until you choose to change them.

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Cross Creek Admissions is committed to protecting your privacy. We provide this Policy as required by law to explain our information practices. It applies to all companies within the Cross Creek family of companies listed at the end of this Policy.

This Policy applies to individuals who ask about and/or obtain products or services from Cross Creek Admissions for personal, family and household purposes. This Policy explains how we collect, use, and secure information, and your right to limit the information we share. If we materially change our information practices in the future, we will notify you of the change.

This Policy describes information practices across Cross Creek Admissions. However, many departments and/or companies within Cross Creek Admissions may have more restrictive information sharing practices than described in this Policy.

This Policy supersedes all previous notices or statements about practices described in this Policy.

COLLECTING INFORMATION 

Cross Creek Admissions collects information to:
  • Accurately identify you;
  • Provide you with products and services;
  • Protect and administer your records, accounts and funds;
  • Design products and services;
  • Understand your financial needs;
  • Save you time in applying for new products and services; and
  • Comply with certain laws and regulations.

Cross Creek Admissions collects information from:
  • Applications and other forms you give us (e.g., name, address, social security number, assets, income and investment objectives);
  • Public sources, such as federal, state or local records (e.g., mortgage and lien information).

Cross Creek Admissions has procedures so that the financial information we collect is correct, current and complete. Cross Creek Admissions is committed to working with you to correct any inaccurate information.

SHARING INFORMATION
Depending on the relationship you have with Cross Creek Admissions, we may share information within the Cross Creek family of companies, as well as with third parties outside Cross Creek Admissions. Cross Creek Admissions reserves the right to share all information we collect as this Policy describes.

Sharing within the Cross Creek family (Internal Sharing) 
Cross Creek Admissions engages in many businesses (e.g., banking, mortgage lending, brokerage and investment services, trust administration, asset management and insurance). We share information internally between these businesses to prevent fraud, enhance services, and tailor products and services.

Sharing with outside companies (External Sharing)
We may share information with selected third parties outside Cross Creek Admissions so they may offer you products and services that may benefit you. These third parties include:
  • Financial service providers, such as mortgage bankers/brokers, insurance agents/companies, securities broker/dealers, indirect loan originators, correspondent lenders, transaction processors;
  • Non-financial companies, such as retailers; and
  • Others, such as nonprofit organizations.

We may share information with marketing partners that include other financial institutions whose products or services we may jointly market under joint marketing agreements from time to time and with third parties outside Cross Creek Admissions who help us market Cross Creek Admissions products and services.

If we share information with third parties, we require them to treat the information in strict confidence and to use it only for the purpose for which it was shared.

OPT OUT EXCEPTIONS
It is important to understand, if you opt out of information sharing, the law still permits Cross Creek Admissions to share certain information about you:

  • With Cross Creek companies and third parties outside Cross Creek Admissions - We may share information as permitted by law, such as:
    • With companies that perform services for us, such as loan servicing;
    • To protect the rights, property or safety of Cross Creek Admissions, our customers or others (such as to protect against fraud and to reduce credit risk);
    • To comply with a legal requirement or process;
    • To comply with your request or authorization to share information; 
  • With other Cross Creek companies - We may share information that identifies you and information on our transactions and experiences with you.

  • With our marketing partners - We may share information with our marketing partners, as described above, to help us market Cross Creek Admissions's products and services to you and, from time to time, to jointly market other financial institutions' products and services.


Former customers
If you end your relationship with Cross Creek Admissions, we will still apply the practices in our policy to information we maintain on you. Your opt out and solicitation decisions stay in effect.

ONLINE INFORMATION PRACTICES 
Cross Creek Admissions uses technology that encrypts, or scrambles, online information so it transfers privately between you and Cross Creek Admissions's network. Your unique log-in ID and password help protect information online. 

Cross Creek Admissions joins with certain third parties to deliver online products and services. If you ask for information through ccpadmissions.com®, Cross Creek Admissions and these outside parties may keep some information you provide so we can deliver these services.

We may keep information from online tools and calculators, online applications and forms, online service subscriptions, or business conducted online through Internet or wireless devices.
  • Online surveys:This information is used solely for research to help us develop a superior Website. We may maintain this information in a form that does not identify you.
  • Email: If you send us email, we may keep the content of your email. Please be careful about the information you email to us, because email to any public website can sometimes be intercepted. If you agree to receive email from Cross Creek Admissions, we keep the information you give us and may use it to send you email messages that specifically interest you.
  • Cookies: A "cookie" tells us our site was visited and which pages were viewed. Cookies are also used for security purposes when you conduct business online. They are common on Websites and do not harm your computer. Cross Creek Admissions uses temporary cookies that do NOT transmit any personal information about you. These are deleted from your computer when you close the browser.
  • Information from children online: Cross Creek Admissions does not market online products and services to children. We take steps to block children from sending us information online.

ADDITIONAL RIGHTS
You may have other privacy protections under state laws. Our information practices comply with these laws.

YOUR OPTIONS

Information Sharing

If you prefer that Cross Creek Admissions not share information about you, you may restrict us from sharing information by opting out. The types of information that we may share, and the categories of companies with which we may share it, are discussed in this Policy. Even if you opt out, we may still continue to share information as explained in the "Opt Out Exceptions" section.

If you wish to opt out, your election can apply to either external information sharing or internal information sharing, or both.
  • External Sharing - information sharing with third party companies that are not part of the Cross Creek family of companies.
  • Internal Sharing - information sharing within the Cross Creek family of companies. If you limit the information Cross Creek Admissions may share within its corporate family, it may restrict our ability to provide you with the best and most comprehensive products and services. For example, we may not be able to offer you more competitive products that may be available to you based on your total Cross Creek Admissions relationship, or offer you certain combined products and statements.

If you choose to opt out, your election will apply to all products and services you obtain within the Cross Creek family of companies. If you have a product or service jointly with another person(s), each of you may opt out individually or you may opt out for each other. If you opt out, we still may share information about a joint party or joint parties unless you or someone else authorized to do so have opted out for that party.

Solicitation Preferences
If you prefer not to receive promotional offers from Cross Creek Admissions, you may record your preferences with us. However, if you have an established relationship with Cross Creek Admissions, you may still be contacted by your account representative(s), and for account related notifications, service and/or support activities.

Recording Your Options
To record or update your information sharing and solicitation preferences with Cross Creek Admissions, or for more information, please call us at our dedicated toll-free Privacy Line:

1-800-808-6228

This policy applies to the following Cross Creek family of companies:
Cross Creek Procgrams LLC, Cross Creek Admissions,   Cross Creek Center.

 

IMPORTANT SUPPLEMENTAL INFORMATION FOR
VERMONT RESIDENTS

This Supplemental Information modifies and supercedes certain provisions of CrossCreek's Privacy Policy for Vermont residents. Except as modified below, the provisions of CrossCreek's Privacy Policy apply to Vermont residents.

For Vermont residents, the "opt out" procedures to limit information sharing described in CrossCreek's Privacy Policy do not apply. Instead, unless you "opt in" to information sharing, we will not disclose information about you to nonaffiliated third parties or to other Cross Creek companies, except as described below under "Permitted Information Sharing Regardless of Opt In."

Permitted Information Sharing Regardless of Opt In
It is important to understand that even if you do not opt in to information sharing, Cross Creek Admissions is still permitted by law to disclose information about you in the following circumstances:

  • To other Cross Creek companies. We may disclose to other companies in the Cross Creek family identification information and information on our own transactions and experiences with you.
  • To our nonaffiliated marketing partners. We may disclose information about you to nonaffiliated third parties that help us to market our own products and services, as well as to other financial institutions with whom we jointly market their products or services. However, the information we may share about you with other financial institutions to jointly market products will be limited to your contact information (such as name, address and phone number) and information about your transactions and experiences with the Cross Creek family of companies.
  • With others, as permitted by law. We may also disclose information about you to other Cross Creek companies and to nonaffiliated third parties when it is permitted by law. For example to comply with a legal requirement or process; to comply with your request or authorization to disclose.

Opt In to Additional Information Sharing
If you wish to opt in to authorize sharing of information in addition to the permitted sharing described above, your opt in authorization can apply to either external information sharing or internal information sharing, or both. External and internal information sharing are described below.

  • External Sharing - Nonaffiliated third parties. You may elect to opt in to information sharing with nonaffiliated third parties (companies that are not part of the Cross Creek family of companies), in addition to those nonaffiliated third parties with which we are otherwise permitted by law to share information, as described above. These additional nonaffiliated third parties may offer you other financial or nonfinancial products and services that could benefit you.
  • Internal Sharing - Cross Creek family of companies. You may elect to opt in to the sharing of all information we have concerning you among the Cross Creek family of companies not limited to the information with which we are otherwise permitted by law to share with our affiliates, as described above. Sharing full information among Cross Creek's family of companies increases your access to our products and services, allows us to match our products and services to your specific needs, as well as simplifies transaction flows.

Your election(s) to opt in will apply to all products and services you obtain within the Cross Creek family of companies for personal, family or household purposes.

Joint Accounts
If you have a product or service jointly with another person(s), we will not disclose information about the joint account pursuant to an opt in authorization, except as otherwise permitted by law, unless all joint accountholders have opted in.

Health or Medical Information
Regardless of whether you have opted in, we will not share any personal health or medical information we may have without your written consent or otherwise as permitted by law. Health or medical information may include insurance application information, other health information you may provide in connection with one or more existing accounts, or information provided to us with regard to an insurance claim.

For More Information, to Opt In or to Revoke a Previous Opt In
If you would like more information about your options, or wish to opt in to information sharing, please call our dedicated Privacy Line toll free at 1-800-808-6228 to request a pre-printed opt in form be mailed to you. If you opt in to information sharing and later wish to revoke that election, you may do so at any time by calling our toll free Privacy Line to change your preference.

Please note: The automatic opt out of information sharing we record on your behalf to comply with Vermont state law will continue for as long as our records indicate you are a Vermont resident. If our records show you no longer reside in Vermont, your information sharing status will revert back to the sharing preference you directly elected with Cross Creek Admissions. For example, if at any time you had called Cross Creek Admissions to opt out of information sharing, that preference will then be effective once the automatic opt out is removed. However, if you have not directly recorded an opt out preference with Cross Creek Admissions, and you want to continue to restrict information sharing after moving outside Vermont, you must do so by calling our Privacy Line.

Please retain a copy of this Supplemental Information, together with the Cross Creek Privacy Policy, for your records. This Supplemental Information may be amended from time to time. You will be notified in writing of any changes.
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