This Policy describes FCI’s collection, use, sharing, and protection of Personal Information. Personal Information, and all other capitalized terms, are defined in the “Glossary” at the end of this Policy. Unless otherwise stated, this Policy applies to all Personal Information whether collected in person, digitally, or via some other medium.

The collection, use, and sharing of Personal Information described in this Policy is required to transact business with FCI. Persons that transact business with FCI (which for purposes of Policy includes the utilization of FCI’s Online Services) individually, through an agent, and/or as agent for another person, agree to the terms of this Policy. Persons that do not agree to the terms of this Policy should not transact business with FCI.

I. Philosophy

FCI directors and employees shall not use or disclose any information, including Personal Information, acquired by virtue of their position as a FCI director or employee unless (i) the information is of a type ordinarily contained in published reports or press releases; (ii) disclosure is authorized by FCA regulation; or (iii) disclosure is necessary in performing a director or employee’s official duties.

To ensure compliance with the above obligations, all FCI employees and directors are required to execute a confidentiality agreement as a condition of employment and participate in annual training of their confidentiality obligations. FCI also implements policies, procedures, and internal controls governing the use, disclosure and security of information within its possession.

II. Personal Information Collected

FCI may collect Personal Information of persons transacting business with FCI. Personal Information collected by FCI includes, but is not limited to:

• Name
• Address
• Telephone Number
• Email Address
• Driver’s License or Identification Card Number
• Social Security Number
• Employment Information
• Education Information
• Financial Information
• Account information
• Account numbers
• Client number
• Passwords
• Personal Identification Numbers (PINs)
• Tax Identification Numbers
• Maiden Name
• Date of Birth
• Usage Details
• Device Information
• Stored Information and Files
• Location Information

III. Methods of Collecting Personal Information

FCI collects Personal Information from the following sources:

• Persons transacting business with FCI.
• Directly and indirectly from FCI’s Online Services. FCI may utilize Cookies, Web Beacons, and similar information collection technologies to collect Personal Information from utilization of FCI’s Online Services or similar technologies.
• From service providers and vendors FCI engages to provide products or services or to enable FCI to provide products and services.
• From FCI’s affiliate companies and strategic partners including other farm credit system institutions with whom persons may conduct business.

IV. Use of Personal Information

FCI uses Personal Information as required for its directors and employees to perform their official duties. FCI will use Personal Information to fulfill the operational and commercial purposes for which the information was collected. It may also use Personal Information to improve its products, services, processes, and operations, while maintaining the confidentiality of the individual to whom the Personal Information relates.

Examples of FCI uses of Personal Information include:

• Providing financing, insurance and other related products;
• Maintaining or servicing customer accounts;
• Processing requests, purchases, transactions, and payments;
• Providing customer service;
• Processing and accounting for payments and disbursements;

• Verifying or maintaining the quality of services or products;
• Engaging in advertising or marketing activities;
• Producing company publications and marketing materials to communicate our products and services to potential customers with the prior knowledge and consent of any individual whose Personal Information is being used for such a purpose;
• Enabling commercial transactions;
• Enabling analytic services;
• Verifying customer, employee or prospective employee information;
• Auditing for compliance with federal and state regulations and laws;
• Auditing related to current interaction with persons and concurrent transactions including, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions and auditing compliance with this specification and other standards;
• Detecting security incidents and protecting against malicious, deceptive, fraudulent or illegal activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration
• Fulfilling regulatory reporting and requirements;
• Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations; and
• Activities as described to, or by, persons when collecting Personal Information.

FCI will not use Personal Information collected for substantively different or unrelated purposes without notifying the person to whom it relates. FCI will not use Personal Information in a way that makes it public unless (i) the information is of a type ordinarily contained in published reports or press releases; (ii) disclosure is necessary in performing a director or employee’s official duties (e.g. identifying a person’s name and address on a mortgage); or (iii) the individual has agreed to public use.

V. Sharing Personal Information

FCI may disclose Personal Information to a service provider or third party for a business purpose. When FCI discloses Personal Information for a business purpose, FCI enters into a written contract describing the purpose for the engagement and requiring that the recipient of any Personal Information keep that Personal Information confidential, unless otherwise agreed by the by the individual to whom the Personal Information pertains, and not use it for any purpose except for performing the services on behalf of FCI as identified in the contract.

FCI shares Personal Information with the following categories of third parties:

• Business partners
• Service providers
• Affiliates
• Third Parties to whom persons authorize FCI to disclose their Personal Information in connection with products or services
• External Marketing Entities
• Advertising Networks
• Data Analytics Providers
• Government Entities
• Research/Academics
• Operating System Platforms
• Social Networks 

FCI will also disclose Personal Information to comply with any court order, law, or legal process, including to respond to any government or regulatory request; to enforce FCI’s contractual rights, including as necessary for billing and collection; and as necessary or appropriate under applicable law to protect the rights, property, or safety of FCI, its customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

VI. Right to Access Personal Information

Individuals may access any of their Personal Information directly maintained by FCI by reaching out to their Relationship Manager or the contact information below. FCI may require that an individual request access through a process set forth by FCI for such access. FCI may restrict access to Personal Information if required by law.

VII. Security

FCI has implemented measures designed to secure Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Personal Information security also depends on the individual to whom Personal Information pertains. Where applicable, individuals are responsible for maintaining the confidentiality of passwords, and other access security services, to FCI’s services and products.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although FCI does its best to protect Personal Information, FCI cannot guarantee the security of Personal Information transmitted through FCI’s Online Services. Any transmission of Personal Information is at the individual’s own risk. FCI is not responsible for circumvention of any privacy settings or security measures outside of the Farm Credit Illinois computer network.

In the event that the security of Personal Information is breached, FCI will provide notices to affected individuals as required by applicable law.

VIII. Online Services

The provisions of this section apply to FCI’s Online Services.

A. Third-Party Web Linking

 FCI may provide links to independent websites maintained by various federal agencies or other organizations, solely as a benefit to its member-owners. These other sites may have their own policies, which FCI does not control. FCI does not endorse, approve or guarantee information, products, services, or recommendations provided at any of the sites to which links are provided.

FCI is not responsible for the content or accuracy of any third-party website and is not responsible for any loss or damage of any sort resulting from the use of a link on any linked websites. FCI is not liable for any failure of products or services advertised or provided on these linked sites. FCI offers these links on an “as is” basis.

This Policy does not apply to websites and apps that are not FCI Online Services.

B. Children Under the Age of 16

 FCI’s Online Services are not intended for children under 16 years of age, and FCI does not knowingly collect Personal Information from children under 16. If FCI learns that it has collected or received Personal Information from a child under 16 via its Online Services without verification of parental consent, FCI will delete that information. Individuals that believe that FCI has any information from or about a child under 16 without parental consent should contact FCI at the contact information listed below.

C. The App’s Collection, Use, and Disclosure of Certain Personal Information

 The App may request permission to the following device features for the following purposes:

• Camera and Images: The App may request permission to access the device’s camera and images to allow for the App’s Remote Check Capture functionality.
• Face Identification: The App may request permission to access the device’s face identification capability to allow for secure sign-on and access to the App.
• Location: The App may request permission to access the device’s map functionality to show nearby FCI locations.

Granting the above-described permission is optional, but refusing said permission will limit the associated functionality. Likewise, you may be able to disable Cookies utilized by FCI’s Online Services, but doing so may affect some of FCI’s Online Service’s functionality. 

IX. Changes to This Policy

FCI reserves the right to update or change this Policy at any time. Individuals engaging with FCI agree to check this Policy periodically and agree to the terms of this Policy as reasonably modified from time to time.

X. Contact Information

Questions or comment about this Policy and/or FCI’s privacy practices may be directed as described below:

• Email: ask@farmcreditil.com
• Telephone: (217) 590-2242

XI. Glossary

The following terms have the following meaning when used in this Privacy Policy:

App means the FCI Online Banking App.

Cookies means small files that your browser places on your device used to access FCI’s Online Services. Cookies help a website remember information about your visit, making it easier to visit the site again and making the site more useful to you.

Device Information means information about the device used to access FCI’s Online Services and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number, if applicable.

FCI means Farm Credit Illinois, ACA, Farm Credit Illinois, FLCA, and Farm Credit Illinois, PCA.

FCI’s Online Services means one, or both, of the App and Website.

Location Information means real-time information about the location of the device used to access FCI’s Online Services.

Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household.

Personal Information does not include publicly available information or information that is deidentified or aggregate consumer information. For purposes of this paragraph, “publicly available” means information that is (i) lawfully made available from open sources like legitimate websites, public or governmental records, or media and (ii) is not behind a paywall or subject to other special permission to view or use it..

Stored Information and Files means metadata and other information associated with other files stored on the device used to access FCI’s Online Services.

Usage Details means information regarding the use of FCI’s Online Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the FCI’s Online Services.

Web Beacon means a transparent graphic image on a webpage or within the body of an email that allows measurement of a visitor actions for assessment.

Website means https://www.farmcreditil.com.