Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident and incudes certain categories of Personal Information discussed below that constitute “Sensitive Personal Information.’” The CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (GLBA).  

The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. For example, this Notice does not apply with respect to information that we collect about California residents who apply for or obtain or financial products and services for personal, family, or household purposes. For more information about how we collect, disclose, and secure information relating to these customers, please refer to our Privacy Notice.  

Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or elsewhere.  

In the past 12 months, we have collected and disclosed for our business purposes each of the following categories of Personal Information relating to California residents covered by this Notice: 

• Identifiers such as a legal name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers;
• Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual including, but not limited to, his or her name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information or health insurance information;
• Characteristics of protected classifications under California or federal law, such as sex and marital status;
• Commercial information, such as records of personal property, products or services purchased, obtained or considered, or tother purchasing or consumer histories or tendencies;
• Biometric Information;
• Internet or other electronic network activity information, such as browsing history, search history, and information regarding a California resident’s interaction with an internet website application, or advertisement;
• Geolocation data, such as device location and Internet Protocol (IP) location;
• Audio, electronic, visual, thermal, or similar information such as call and video recordings;
• Professional or employment-related to a student; and maintained by an educational agency or institution or by a party acting for the agency or institution;
• Inferences drawn from any of the Personal Information listed above to create a profile about a California resident reflecting their preferences, characteristics, psychological trends, predispositions, behavior, and attitudes, intelligence, abilities, and aptitudes; and 
• The following categories of Sensitive Personal Information: 
  • Personal Information that reveals:
    • A California residents’ Social Security number, driver’s license, state identification card, or passport number;
    • A California resident’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
    • A California resident’s precise geolocation;
    • A California resident’s racial or ethnic origin, religious or philosophical beliefs, or union membership;
    • The contents of a California resident’s mail, email, and text messages unless the business is the intended recipient of the communication;
  • The processing of biometric information for the purpose of uniquely identifying a California resident; and
  • Personal information collected and analyzed concerning a California resident’s health.

In addition to collecting Personal Information ourselves, we additionally coordinate with third parties to collect Personal Information on our behalf, these third parties are engaged in one or more of the business practices described below: 

• Delivering or advertising and marketing, including on non-affiliated person’s or entities’ sites and mobile apps; 
• Facilitating events and event management, including virtual and/or in-person events;
• Referral sources, whether for purposes of identifying candidates for employment, identifying new client opportunities, or recommending vendors or contractors. 

The categories of sources from which we collected Personal Information are; 

• Directly from a California resident or the individual’s representatives; 
• Service Providers, Consumer Data Resellers, Credit Reporting Agencies and other similar persons or entities;
• Public Record Sources (Federal, State or Local Government Sources);
• Information from our Affiliates;
• Website/Mobile App Activity/Social Media;
• Information from Client Directed persons or entities or Institutions representing a customer or prospective customer; and 

With respect to each category of Personal Information that we disclosed for a business purpose in the past 12 months, the categories of persons or entities to whom we disclosed that Personal Information are; 

• Affiliates of First Fed; 
• Service Providers and Contractors who provide services such as payment, banking and communication infrastructure, storage, legal expertise, tax expertise, real estate expertise, appraisal expertise, notaries and auditors, who promote the bank and its financial services and products;
• Other Service Providers and Contractors who enable customers to conduct transactions online and via mobile devices, support mortgage and fulfillment services, vehicle loan processes, and aggregators (at the direction of the customer);
• Other persons or entities to whom we transfer Personal Information as an asset that is part of a merger, acquisition or other transaction in which such other person or entity assumes control of all or part of the business;
• Government agencies as required by law or regulations; and 
• Other persons or entities with which you may use or direct us to intentionally interact or to which you may use or direct us to intentionally disclose your Personal Information. 

We do not disclose Personal Information to any other categories of third parties. 

We collect, use and disclose for our business purposes Personal Information, including Sensitive Personal Information, relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business or commercial purposes, including the following:  

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services (excluding for cross -context behavior advertising, a type of targeted advertising), providing analytic services, facilitating event management and execution, managing our real estate portfolio, or providing similar services; 
• Helping to ensure security and integrity to the extent the use of Personal Information is reasonably necessary and proportionate for these purposes;
• Short-term transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us, where the information is not disclosed to a third party and is not used to build a profile, or otherwise alter the California resident’s experience outside the current interaction with us;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance that service;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration; and
• Complying with laws and regulations and complying with other legal processes and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions).

How Long We Retain Personal Information

We only use or disclose Sensitive Personal Information for the following purposes consistent with CCPA Regulations:  

• To perform the services or provide the goods expected by an average California resident who requests those goods or services. For example, a California resident’s precise geolocation may be used by a mobile application that provides them with directions on how to get to a specific location.  
• To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted Personal information, provided that the use of a California resident’s Personal Information is necessary and proportionate for this purpose. For example, we may disclose a California resident’s log-in information to a data security company that we have hired to investigate and remediate a data breach that involved that individual’s account. 
• To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions, provided that the use of a California resident’s Personal Information is necessary and proportionate for this purpose. For example, we may use information about a California resident’s ethnicity and/or the contests of email and text messages to investigate claims of racial discrimination or hate speech.
• To ensure the physical safety of natural persons, provided that the use of California resident’s Personal Information is necessary and proportionate for this purpose, for example, we may disclose a California resident’s geolocation information not law enforcement to investigate an alleged kidnapping. 
• For short-term, transient use, including non-personalized advertising shown as part of a California resident’s current interaction with us.
• To perform services such as maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying a California resident’s information, processing payments, providing financing, providing analytic services, and providing storage. 
• To verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured f or, or controlled by us.  

If you are a California resident covered by the CCPA, you have the right to:

1. Receive this Notice at or before the point of collection of your Personal Information.  
2. Request that we disclose to you free of charge the following information covering the 12 months preceding your request: 
   • the categories of Personal Information about you that we collected;
   • the categories of sources from which the Personal Information was collected;
   • the purpose for collecting Personal Information about you;
   • the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that were disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and 
   • the specific pieces of Personal Information we collected about you;
3. Request we correct inaccurate Personal Information that we maintain about you. 
4. Request we delete Personal Information we collected from you, unless the CCPA recognizes an exception. 
5. Be free from unlawful discrimination for exercising your rights under the CCPA.  

Please see the section below entitled, “How to Exercise Your Rights,” for instructions explaining how you can exercise these rights described above.  

We will acknowledge receipt of your request and advise you how long it will take to respond if we can verify your identity. Requests for specific pieces of Personal Information will require additional information not verify your identity.  

For individuals submitting a request on behalf of another person, we may require proof of authorization from the individual such as a Power of Attorney and verification of identity directly from the person for whom the request is made.  

In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights.  

We will advise you in our response if we are not able to honor your request. We will not provide Social Security numbers, driver’s license numbers of government-issued identification numbers, financial account numbers, unique biometric data, health care or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.   

We will work to process all verified request within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days, to process your request, we will provide you with an explanation for the delay.