California Consumer Privacy Act

California Consumer Privacy Statement

For MUFG, Union Bank, and PurePoint

Effective January 1, 2020

This California Consumer Privacy Statement supplements the MUFG Americas Personal Information Protection Policy, Union Bank Privacy Policy, PurePoint Financial Privacy Policy and other relevant privacy policies of affiliated Mitsubishi UFJ Financial Group, Inc. entities (collectively, “Privacy Policies”).  It applies solely to California consumers and addresses personal information we collect online and offline.  This Statement does not apply to MUFG personnel or job applicants or information collected, processed or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1.    Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you :

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, and military and veteran status
  • Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
  • Sensory Information: audio, electronic, visual, and similar information
  • Employment Information: professional or employment-related information
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in our Privacy Policies.  In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table: 

Purposes
Categories of Personal Information
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Sensory Information
• Employment Information
• Inferences
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
• Identifiers
• Commercial Information
• Online Activity
• Inferences
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
• Identifiers
• Commercial Information
• Online Activity
• Inferences
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Sensory Information
• Employment Information
• Inferences
Debugging to identify and repair errors that impair existing intended functionality
• Identifiers
• Commercial Information
• Online Activity
• Inferences
Undertaking internal research for technological development and demonstration
• Identifiers
• Commercial Information
• Online Activity
• Inferences
Undertaking activities 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, manufactured for, or controlled by us
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Sensory Information
• Employment Information
• Inferences

2. Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement.   For  the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.

a. Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection
Categories of Personal Information
Directly from you
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Sensory Information
• Employment Information
From your devices, such as when you visit our websites, online and mobile applications
• Identifiers
• Commercial Information
• Online Activity
• Inferences
Other individuals, such as authorized agents or family members
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Sensory Information
• Employment Information
Our affiliates
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Sensory Information
• Employment Information
• Inferences
Vendors who provide services on our behalf
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Sensory Information
• Employment Information
• Inferences
Our joint marketing partners
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Commercial Information
• Online Activity
• Inferences
Social Networks
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Employment Information
• Inferences
Government entities and other publicly-available sources
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Employment Information
Consumer data resellers
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Employment Information

b. Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties
Categories of Personal Information
Our affiliates
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Sensory Information
• Employment Information
• Inferences
Vendors who provide services on our behalf
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Sensory Information
• Employment Information
• Inferences
Professional services organizations, such as auditors and law firms
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Sensory Information
• Employment Information
• Inferences
Our joint marketing partners
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Commercial Information
• Online Activity
• Inferences
Our business partners
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Employment Information
• Inferences
Advertising networks
• Identifiers
• Commercial Information
• Online Activity
• Inferences
Internet service providers
• Identifiers
• Commercial Information
• Online Activity
• Inferences
Data analytics providers
• Identifiers
• Commercial Information
• Online Activity
• Inferences
Government entities
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Commercial Information
• Online Activity
• Sensory Information
• Employment Information
• Inferences
Operating Systems and platforms
• Identifiers
• Commercial Information
• Online Activity
• Inferences
Social networks
• Identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80
• Protected Classifications
• Online Activity
• Employment Information
• Inferences
Consumer data resellers
• Identifiers
• Commercial Information
• Online Activity
• Inferences

c. Sale of Personal Information

We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies on our websites such as to enhance the ability to serve you content and advertisements that may be of interest to you. You have the right to opt out of this disclosure of your information, as detailed below.

During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have sold the following categories of personal information:

  • Identifiers such as a unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology), online identifier, and internet protocol address

  • Commercial information, including records of personal property, products or services considered, and other purchasing or consuming histories or tendencies

  • Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements

  • Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.

d.    Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties the following categories of personal information for a business purpose :

  • Identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Protected Classifications
  • Commercial Information
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences

3.    California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.  
 

Deletion: You have the right to request that we delete certain personal information we have collected from you.
 

Opt-Out of Sale: You have the right to opt-out  of the sale of your personal information.

How to Submit a Request. To submit an access or deletion request, click on the "Submit a Request" at the bottom of this page or call toll-free at 1-888-283-6699 (our menu will prompt you through your choices) Monday-Friday 7am(pst) - 9:00pm(pst) and Saturday 8am(pst) - 5pm(pst).

To opt-out of the sale of your personal information, visit UnionBank, PurePoint and MUFGAmericas, click on ‘Do not sell my info’ in the footer of each website. If you would like to opt-out of the sale of your personal information associated with a different device or browser, please submit an opt-out request using that device or browser. Please note that if you clear your cookies on a particular browser or device, you may need to resubmit your opt-out request again from that device or browser. For more information on how to opt-out of the sale of your personal information call toll-free at 1-888-283-6699 (our menu will prompt you through your choices) Monday-Friday 7am(pst) - 9:00pm(pst) and Saturday 8am(pst) - 5pm(pst).

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.  If you request access to or deletion of your personal information, we may require you to provide any of the following information: name, date of birth, email address, telephone number, or postal address.  In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.   If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.   To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.  This Statement is available in alternative formats upon request.  Please contact [email protected] or call toll-free at 1-888-283-6699.  For TDD hearing-impaired assistance through Relay Service, dial 7-1-1; provide the Relay Operator with 1-800-238-4486 or Teletypewriter (TTY) 1-800-826-7345.

Submit a request