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:
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Accurately identify you;
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Provide you with products and services;
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Protect and administer your records, accounts and funds;
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Design products and services;
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Understand your financial needs;
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Save you time in applying for new products and services; and
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Comply with certain laws and regulations.
Cross Creek Admissions collects information from:
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Applications and other forms you give us (e.g., name, address, social security
number, assets, income and investment objectives);
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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:
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Financial service providers, such as mortgage bankers/brokers, insurance
agents/companies, securities broker/dealers, indirect loan originators,
correspondent lenders, transaction processors;
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Non-financial companies, such as retailers; and
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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:
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With Cross Creek companies and third parties outside Cross Creek
Admissions - We may share information as permitted by law, such as:
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With companies that perform services for us, such as loan servicing;
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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);
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To comply with a legal requirement or process;
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To comply with your request or authorization to share information;
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With other Cross Creek companies - We may share information that
identifies you and information on our transactions and experiences with you.
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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.
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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.
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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.
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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.
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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.
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External Sharing
- information sharing with third party companies that are not part of
the Cross Creek family of companies.
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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:
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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.
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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.
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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.
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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.
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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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