Privacy Statement

Last updated: September 3, 2024

Protecting your privacy is important to us. This Privacy Statement and other disclosures detail how Compeer Financial, ACA/FLCA/PCA (“Compeer Financial”, “us”, “we” or “our”) and its business units collect, use, protect, and disclose your Personal Information. 

Personal Information includes information linked or reasonably linkable to an identified or identifiable individual, including but not limited to nonpublic:

• Account information
• Account numbers
• Client number
• Credit card numbers
• Email
• Loan number
• Name
• Passwords
• Personal identification numbers (PINs)
• Phone number
• Physical Address
• Social Security number or tax identification number

Personal Information does not include anonymized data which does not identify an individual. 

Security Statement

We are committed to the security of your Personal Information.  Policies, procedures, and internal controls are in place 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 chat or standard email.  Please do not communicate any sensitive or confidential Personal Information (such as your Social Security number) through unsecure or unencrypted channels. We will never ask you to update, validate or in any other way request Personal Information via standard email, chat, or other unsecure channels.

We retain Personal Information, along with other business information, for legal, auditing, regulatory, and business purposes.

Information Collection

Information you provide

We collect the Personal Information that you provide to us through applications and other forms or inquiries related to our products, transaction with us, through web-based technologies regarding device usage (see below), and through conversations with Compeer team members. If you choose to send us a contact request, chat, or other communication with information about yourself, we may maintain records of your correspondence. 

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.

Device and Usage Information

Compeer Financial operates www.compeer.com, rates.compeer.com, pages.compeer.com and my.compeer.com (collectively, the “Site”). The Site automatically collects information through your use of the Site, such as the following:

• Transactions or Communications: We collect information regarding account access, chat, payments and transactions, applications, and underwriting.
• Usage Information: We collect certain information such as which of the pages on our Site that you access, the time and date of access, the frequency of access, and which parts of our Site you view.
• Location Information: When you use the Site, we may collect information about your physical location. We 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 also use tools such as UTMs or Google Analytics to inform, optimize, and/or serve ads based each visit to our Site and analyze uses of advertisement services, and interactions with these ad services are related to visits to our Site.
• Mobile Device Information: When you access our Site 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 Medial Information: Our Site may also include social media features, such as the Facebook “Like” button, and other widgets, such as the “Share” button or interactive mini-programs provided by third parties. These third parties may provide cookies or other tracking technologies to collect information about you when you use our Site.

For the avoidance of doubt, like many sites, we may use session and/or persistent “cookies”, UTMs, pixels, web beacons, local shared objects, and other tracking technologies for various purposes such as storing information if you are registered with our Site, better understand the interests of our clients and our Site visitors, fraud prevention and monitoring our marketing campaigns.   The information collected may be associated with your Personal Information or and connect data about your online activities over time and across different websites and other online services. 

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

You can find information about how to determine the technologies currently enabled regarding your online and mobile activity and how to opt-out of some of those technologies by accessing the Network Advertising Initiative's website at Home - NAI: Network Advertising Initiative (thenai.org); or the Digital Advertising Alliance's website at DigitalAdvertisingAlliance.org from your browser. 

How We Use and Share Information

We use Personal Information that we collect in the following ways: 

• Applications and Transactions: We may use your Personal Information to underwrite and rate your applications and accounts, or process other transactions. 
• Provide Services: We use your Personal Information in order to provide proper billing, offer you our services, fulfill our other contractual obligations to you, and/or enforce our rights arising from contracts with you.
• Communicate: We use Personal Information to communicate with you about our Site 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 Site 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.
• Marketing: We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information. All marketing and promotional communications will provide an opt-out method as described within the communications channel. 
• Online Advertising We may work with online advertising companies to share useful web ads, where applicable. Which advertisements you see is often determined using the information we or our affiliates, service providers, and/or business partners have about you, including information about your relationships with us (e.g., types of accounts held, transactional information, location of banking activity). This is called "online behavioral advertising." Some online behavioral advertising companies may have information sufficient to identify you.  To that end, where permitted by applicable law, we may share with others the information we collect from and about you.  If you do not want your information collected and used for online advertising, you can control certain preferences by following the instructions in the prior section.
• Synthesis and 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 dataset (de-identified data).  We develop de-identified data to analyze or understand more about our clients or agribusiness, or for other commercial purposes as permitted by law.  For example, we may calculate the percentage of clients in a particular ZIP code.
• 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 Site to maintain and improve it.  

We may share information, including Personal Information about you and our transactions and business interactions with you with third parties, as described below:

• Business Partnerships: We may share your Personal Information with other business partners that jointly participate in underwriting, loan disbursement, payment or other business activities.
• Service Providers: We may share Personal Information with service providers that help us with day-to-day business operations, and to administer our services, communications, and Site functions. All such service providers agree to (and are obligated to) maintain the confidentiality and security of information.  For example, we may share your information with third-party customer service providers.
• Consumer Reporting Agencies:  We may share Personal Information with consumer reporting agencies in order to obtain information about your credit history or to report information to the agencies about your credit transactions with Compeer.
• Corporate Family: We may share information within our corporate family, such as with subsidiaries, joint ventures, or affiliates, to the extent permitted by law.
• Corporate Structure: We may share information in connection with a merger, acquisition, consolidation, change of control, or sale of all or a portion of our assets or if we undergo bankruptcy or liquidation.
• To Prevent Harm: We may share information if we believe it is necessary in order to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.
• For Legal Purposes: We will share information where we are legally required to do so, such as in response to requests from our regulator, other Farm Credit associations for purposes allowed by law, court orders or legal process, to establish, protect, or exercise our legal rights, to defend against legal claims or demands, or to comply with the requirements of any mandatory applicable law.
• With Your Consent: We may request your permission to share your Personal Information for a specific purpose. We will notify you and request consent before you provide the Personal Information or before the Personal Information you have already provided is shared for such purpose.  

Borrower Privacy Under the Farm Credit Act

Since 1972, Farm Credit Administration (“FCA”) regulations have generally restricted the disclosure of most types of information provided to us by a loan applicant (“Personal Borrower Information”) without your consent. Consistent with those rules, we may disclose your Personal Borrower Information and other Personal Information only to our employees, contractors, agents, affiliates, third-party service providers, independent auditors, regulators, consultants or attorneys, or to any third-party assisting Compeer with its business processes, as described above.

Children’s Online Privacy Protection Act 

We do not knowingly collect, use or maintain any information through the Site from or pertaining to children who are under the age of 13 years. If we determine that a child under the age of 13 years has provided us with information through the Site, we will only use this information to notify the parents that this information was received, and such information will be deleted. If you believe we might have any information from a child under the age of 13 years, you may contact us at [email protected] or by calling 844-426-6733.

Browser Do Not Track 

The Site is not currently configured to respond to Do Not Track signals. 

Links to Third-Party Websites

The Site may contain links to third-party websites that are not owned or controlled by us. While we may provide links on the Site to other websites of interest we cannot endorse, approve or guarantee the information, products, services or recommendations provided on any third-party website. When you visit a third-party website by using a link from our website, you will no longer be protected by our privacy or security statements and practices. Your use of such linked websites is subject to the terms and conditions and privacy policies of the providers of those websites; therefore we encourage you to familiarize yourself with their privacy and security practices.

Changes to This Privacy Statement

We reserve the right to update or change our Privacy Statement at any time, and you should check this Privacy Statement periodically. Your continued use of the Site after we post any modifications to the Privacy Statement on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Statement.

Contact Us

If you have any questions or would like to make a request regarding this Privacy Statement, please contact us.

Phone: 844-426-6733

Email: [email protected]

Mail:

Compeer Financial

2600 Jenny Wren Trail

PO Box 810

Sun Prairie, WI 53590 

California-Specific Description of Consumers’ Privacy Rights

This California-specific Privacy Policy (“Policy”), which supplements our Privacy Statement, describes the rights California residents (“consumers”) have over their personal information pursuant to the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100-1798.199 (“CCPA”). 

We collect personal information in connection with both consumer and commercial clients and prospective clients. The term “consumer” in this Policy shall not be construed to limit the applicability of this Policy to consumer purpose accounts. 

Right to Know

A consumer has the right to request the following:

• The categories of personal information we have collected about that consumer.
• The categories of sources from which the personal information is collected.
• Our business or commercial purpose for collecting or selling personal information.
• The categories of third parties with whom we share personal information.
• The specific pieces of personal information we have collected about that consumer.  

A consumer has the right to request that a business that sells the consumer’s personal information, or that discloses it for a business purpose, disclose to that consumer:

• The categories of personal information sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
• The categories of personal information disclosed about the consumer for a business purpose. 

Right to Delete

A consumer has the right to request the deletion of their personal information collected by us. 

We may deny a consumer’s request to delete in order to:

• Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of our ongoing business relationship with the consumer, or otherwise perform a contract between us and the consumer.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the applicable provision of the California Electronic Communications Privacy Act.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
• Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with us.
• Comply with a legal obligation.
• Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Right to Opt-Out

A consumer has the right, at any time, to opt-out of the sale of their personal information. 

Right to Non-Discrimination

Finally, we will not discriminate against a consumer because the consumer exercised any of the consumer’s rights under CCPA, including, but not limited to, by:

• Denying goods or services to the consumer.
• Charging different prices or rates for goods or services, such as discounts or other benefits or imposing penalties.
• Providing a different level or quality of goods or services to the consumer.
• Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.  

 Categories of Personal Information Collected or Disclosed

We have collected or may have disclosed the following categories of personal information about consumers for a business or commercial purpose in the preceding 12 months:

Category	Examples	Collected?	Disclosed?
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes	Yes
B. Personal information categories described in Cal. Civ. Code § 1798.80(e).	A 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. Some personal information included in this category may overlap with other categories.	Yes	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes	Yes
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	Yes
E. Biometric information.	Genetic, psychological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, and voiceprints, oros or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes	Yes
G. Geolocation data.	Physical location or movements.	Yes	No
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information	Yes	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	Yes	No
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes	Yes

Sources of Personal Information

We collect personal information about consumers from:  

• Consumers directly.
• Credit reporting agencies.
• Financial institutions.
• Government sources from which public records are maintained.
• Legal entities established pursuant to the Farm Credit Act of 1971, as amended.
• Our business partners.
• Service providers with whom we have a contractual relationship. 

Personal Information Collection Purposes

We collect personal information directly from consumers in order to provide them with loans and other products or services within the scope of our charter as an association of the Farm Credit System. This requires us to verify the identity of our clients and determine their ability to borrow for which we collect personal information. For example, it is Compeer’s policy to obtain a copy of each client’s government-issued identification, such as a driver’s license. We also collect tax identification numbers to uniquely identify our clients. Additionally, Compeer collects balance sheets from our clients through our secure portal or by mail.  

Similarly, we collect personal information from credit reporting agencies in contemplation of the extension of credit, administration of credit, or the collection of loans. This may include a loan applicant’s income and payment history, debts, and other financial information to assess the applicant’s capacity to repay debts. 

We also collect personal information about consumers from financial institutions and legal entities established pursuant to the Farm Credit Act of 1971, as amended, that we partner with to provide financial services to consumers.

When a client signs documents electronically with Compeer, our electronic signature platform automatically collects data to verify the location of a signer. Additionally, when a client closes a loan or other transaction using our remote online notarization service, we are required to maintain a recording of the audio-video session for a period determined by state law. Additionally, we collect personal information, including employment-related information, from our employees and job applicants for human resources purposes.

We also collect contact information from clients and prospects to communicate with them regarding their account, share industry insights, notify them or Compeer events, participate in director elections, and to market products and services. 

Personal Information Disclosed

We may disclose personal information for business or commercial purposes. It is our policy not to disclose or make available any personal information or other sensitive information unless we have entered into a contract with the party receiving the information to keep such information confidential and not to use it for any purpose except as described in the contract or as otherwise agreed to or directed by the consumer. 

We disclose personal information for business purposes to the following categories of third parties:

• Credit reporting agencies.
• Financial institutions.
• Legal entities established pursuant to the Farm Credit Act of 1971, as amended.
• Our business partners.
• Service providers with whom we partner to offer products and services.  

Categories of Personal Information Sold

We have not sold personal information in the preceding 12 months.
  
Designated Methods for Submitting a Request

Personal information requests may be made by using this webform, emailing [email protected], or by calling us at 844-426-6733.
  
 Consumers making personal information requests by phone or email should clearly communicate their specific request (i.e. request to know categories of personal information collected; request to know specific pieces of personal information collected; request to delete personal information; to opt-out) and provide the consumer’s full name, residential address, email address, and telephone number. We will only use information provided by a consumer making a CCPA-related request for the specific purpose of handling consumer inquiries about our privacy practices or ensuring our compliance with CCPA.
  
 All employees responsible for handling consumer inquiries about our privacy practices or our compliance with CCPA are informed of all applicable statutory requirements and how to direct consumers to exercise their rights under the law.

Requests Submitted by Authorized Agents
 

When a consumer uses an authorized agent to submit a request to know or a request to delete, we will require the consumer to directly confirm that they provided the authorized agent permission to submit the request by requiring a copy of the written and signed permission given by the consumer to the authorized agent. We will also require the consumer to verify their own identity directly with us. In accordance with FCA regulations (12 C.F.R. Part 618, Subpart G) and CCPA § 1798.196, we may only provide personal information directly to a consumer if that consumer is a borrower for purposes of Farm Credit Administration regulations, regardless if the request was submitted by an authorized agent on behalf of such borrower.