Privacy Policy

Privacy Notice

ValorFI Heroes, powered by Gesa Credit Union (hereinafter “ValorFI,” “we,” “us,” or “our”) respects your privacy. This Privacy Notice (“Notice”) describes the processing of Personal Information (defined below) that is provided, collected, or disclosed while providing our products or services to you (“Services”) and on the websites, mobile applications, and online platforms that link to this Notice (including https://valorfiheroes.com/) (collectively, “Site”). It also describes rights you may have under applicable laws. Please read this Notice carefully to understand our policies and practices regarding your Personal Information and how we will treat it.

If you are a U.S. consumer and obtain a financial product or service from us, we collect, use, and share nonpublic personal financial information in accordance with applicable GLBA privacy notices, which describe your rights and choices regarding such information. This Notice does not apply to nonpublic personal financial information. For information about ValorFI Heroes’ practices with respect to nonpublic personal financial information, please see ValorFI’s Heroes’ GLBA Privacy Notice.

Personal Information We Collect

“Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. The categories of Personal Information we collect may include:

• Contact Information – If you apply to open an account, contact us, or otherwise provide information on or through our Site or Services, we may collect your contact information including your name, mailing address, email address, and phone number.
• Commercial Information – If you submit an inquiry, or provide information on our Site, we may collect commercial information including information about Services you have shown interest in.
• Account Information – If you apply to open an account or log in to your account, we may collect account information such as your username and password, name, username, nickname, account number, picture, social security number or tax ID, birthdate, zip code, address, phone number, government-issued ID, and information related to your transactions, transfers, travel notifications, account details, analytics, tax information, account authentication, account identifiers, and other information necessary to administer and secure your account.
• Usage Information – When you use our Site, we may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the website you visited before coming to our Site), domain names associated with your internet service provider, and any other information regarding your interaction with our Site.
• Communication Information – We may collect Personal Information contained within your communications with us via email, chat functionality, social media, telephone, or otherwise, and in certain cases we may use third-party service providers to do so. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality.

How We Collect Personal Information

• Directly From You – We collect Personal Information that you provide to us directly, for example, if you choose to apply to open or maintain an account, contact us, or otherwise utilize our Site or Services.
• From Third Parties – We may collect Personal Information from third parties, including but not limited to business partners, advertising networks, social networks, data analytics providers, mobile device providers, and Internet or mobile service providers.
• Through Online Tracking Technologies – We use cookies and similar technologies to collect Personal Information automatically as you navigate our Site. For additional information regarding our use of these technologies, see the Cookies and Tracking Technologies section below.

How We Use Personal Information

To the extent permitted by applicable law, we use Personal Information:

• To provide our Site and Services, including enabling access to and use of our Site and mobile applications; processing and posting transactions; maintaining, servicing, and administering customer accounts; processing payments and transfers; verifying customer identity and information; authenticating users; providing customer support; creating and maintaining business and compliance records; determining eligibility for products and Services; and performing related services.
• To optimize, improve, and maintain our Services, including understanding how users interact with our Services, gauging user interest in certain Services or Site functionality, and troubleshooting problems.
• For marketing and advertising, including using your information to send you messages, notices, newsletters, surveys, promotions, or event invitations about our own or third parties’ goods and services that may be of interest to you. We also use Personal Information to conduct interest-based advertising as discussed in the Cookies and Other Tracking Technologies section below. You can also unsubscribe from any marketing emails that we may send you by following the instructions included in the email correspondence. If you opt-in to receive marketing text messages, you can opt-out at any time by texting “STOP” to 51283. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to resubscribe to marketing text messaging, you will have to complete an opt-in form again. For additional help, text HELP to 51283, email AskUs@gesa.com, or call (888) 946-4372.
• For communicating with you, such as responding to your questions and comments or notifying you of changes to our Site or Services.
• For legal, security, or safety reasons, such as protecting our and our users’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
• As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another another business’ assets, or another corporate transaction, including bankruptcy.
• To fulfill any other purpose for which you provide it, including purposes described when you provide the information or give your consent.

How We Disclose Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose your Personal Information with your consent or in the following circumstances:

• Employees and Other Personnel – We may share Personal Information with our employees and personnel (such as contractors) who have a need to know the information for our business purposes.
• Service Providers – We disclose your Personal Information with the service providers that we use to support our business, including but not limited to, data analytics providers, website hosting providers, and other technology providers. If you are applying for a job with us, this may include service providers such as background check providers and human resource providers.
• Business Partners – We may disclose Personal Information with trusted business partners. For example, we may disclose your Personal Information with a company whose products or services we think may be of interest to you or who we co-sponsor a promotion or service with.
• Ad Tech Companies and Other Providers – We may share or make available limited Personal Information (such as mobile device identifiers) with ad tech companies and other online service providers. When we share your Personal Information in this context, we follow applicable legal requirements, which may require that we provide opt-out rights or other individual rights.
• Legal Obligation or Safety Reasons – We may disclose Personal Information to a third party when we have a good faith belief that such disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of ValorFI, its employees and clients, or the public against harm.
• Merger or Change of Control – We may disclose Personal Information to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving a change of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where legally required, we will give you notice prior to such disclosure.
• Other – We may disclose Personal Information to third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

Cookies and Other Tracking Technologies

We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Site. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Site, to enhance your experience through personalization, and to help us better understand the features of our Site that you and other users are most interested in.

Website Delivery and Appearance

We may use third-party providers to enable certain customer interaction opportunities, content delivery (like audio or video), or other service capabilities. Examples include, but are not limited to, the following functionality:

• Content Delivery: We partner with service providers to host our Site and deliver specific content in support of our Services. For example, we partner with companies like Vimeo to deliver specific content delivery like audio and video.
• Customer Interaction: We enhance our customer interactions by offering features like Google Maps to locate our Service locations, payment processors to facilitate online payments. Each of these offerings are governed by the terms, conditions, and policies of the underlying service provider. For example, please see Google Maps/Google Earth Terms of Service and Google’s Privacy Policy for more information on how that feature operates.
• Chat-based Customer Support: We use a live chat feature powered by a third party to enable live customer service and technical support via our Site. When you engage in the live chat enabled by this service provider, we will automatically collect and share certain information (such as personal identifiers, usage information, and message content) with the vendor to provide the customer service and technical support enabled by the live chat tool.

Website Analytics and Session Replay

We use analytics and session replay services, that use cookies and other technologies that collect your Personal Information, to assist us with analyzing our Site traffic and site usage to optimize, maintain, and secure our Site and inform subsequent business decisions (including, e.g., advertising). These include, but are not limited to, the following third-party services:

• Microsoft Clarity: We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our Site through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Site usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
• Google Analytics: To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
• Pixels: We use Meta, LinkedIn, and TikTok pixels to track user activity on our Site and improve downstream offerings, including interest-based advertising for our services and those of our partners and service providers.

Interest-Based Advertising

We may also allow or enable third parties to collect Personal Information to provide their interest-based advertising on behalf of our products and services, or their own. Interest-based advertising occurs when advertisements are shown to you based on information collected from your online interactions over time and across multiple websites, devices, or online services that you visit or use. Some companies may engage in cross-context behavioral advertising to predict your preferences and show you advertisements that are most likely to be of interest or relevant to you.

We do not control these third parties’ collection or use of your information for these purposes, or the opt-out options they may individually offer you via their terms, conditions, and privacy policies. If you have any questions about an advertisement or other targeted content, you should contact the applicable provider directly. Examples of the third-party service providers we engage to serve interest-based advertisements include Google Ads (including Google Dynamic Remarketing, Google Signals, Google Marketing Platform, and Google AdWords Conversion), Meta Ads (including Meta Pixels and Facebook advertising services), LinkedIn marketing solutions (including LinkedIn Ads, Pixels, and Analytics), and Microsoft Advertising. It is in this context that we may provide advertising networks, data analytics providers, social networks, and video sharing platforms with Personal Information such as your IP address, device information, Internet and other electronic network activity information, and geolocation information in the last twelve months.

Selling Personal Information

While we do not sell Personal Information in exchange for monetary consideration, we do disclose Personal Information for other benefits that could be deemed a “sale” under various data protection laws because it is sometimes broadly defined to include activities such as the delivery of interest-based advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior.

Cookie Choices

To manage your preferences with respect to these technologies, you can:

• Change your cookie preferences in our consent management platform, adjust your browser settings to refuse all or some cookies, or configure your browser to alert you when websites set or access cookies. If you disable certain cookies, please note that some parts of our Site may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.
• Block the collection and use of your information by online platforms and ad tech companies for the purpose of serving interest-based advertising by visiting the opt out pages of the self-regulatory programs of which those companies are members: Network Advertising Initiative and Digital Advertising Alliance. Please note that even if you opt out of interest-based advertising, you may still see “contextual” ads which are based on the context of what you are looking at on the websites and pages you visit.
• Review and execute any provider-specific instructions to customize your preferences or opt-out of certain processing, including interest-based advertising, by third-party service providers. For example, to opt-out of this type of advertising by Google, customize your ad preferences, or limit Google’s collection or use of your data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Meta also offers an Ad Preferences center to customize your settings, as well as a Privacy Policy with additional information on how you can exercise your rights.

Accessing and Correcting Your Information

You may send us an email at AskUs@gesa.com to make a request to access, correct, or delete any Personal Information that you have provided to us. Please note that we may need to verify your identity before considering a request and that we may deny certain requests, or only fulfill some in part, as permitted or required by law. We will not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

How Long We Keep Your Personal Information

We retain your Personal Information for as long as needed: (i) to conduct business with you; (ii) fulfill the purposes outlined in this Notice; and (iii) to comply with our legal obligations, resolve disputes, and enforce any agreements. Criteria we will use to determine how long to retain your Personal Information include the nature and length of our business relationship with you; our legal rights, obligations, and retention requirements; and if we have an ongoing business purpose for retaining your Personal Information.

Links to Third-Party Websites

We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be handled in accordance with the applicable third party’s privacy policy.

In some cases, we offer links to social media platforms (like Facebook, Instagram, X, Vimeo, and LinkedIn) that enable you to easily connect with us or share information on social media. Any content you post via these social media pages is subject to the Terms of Use and Privacy Policies for those platforms. In addition, if you access or download our mobile application through the Apple App Store or Google Play Store, those platforms may collect information about you in accordance with their own privacy policies, over which we have no control.

International Use

If you are visiting our Site from outside of the United States, please note that our Site is hosted in the United States. Where permitted by applicable law, we may transfer the Personal Information we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Notice.

How We Protect Personal Information

We have implemented commercially reasonable measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Despite these efforts to store Personal Information in a secure environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems.

Children’s Privacy

We do not knowingly collect or solicit any Personal Information from children, as defined under applicable law, without verified written parental consent, and we have no actual knowledge of selling such Personal Information of minors under 16 years of age. If we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you believe we might have any information from or about a child, please contact us at AskUs@gesa.com.

Changes to this Notice

Please note that we may modify or update this Notice from time to time, so please review it periodically. If we make material changes to how we treat Personal Information, we will notify you according to applicable law. Unless otherwise indicated, any changes to this Notice will apply immediately upon posting to our Site. You are responsible for periodically visiting our Site and this Notice to check for any changes.

Contact Us

If you have any questions about our practices or this Notice, please contact us at AskUs@gesa.com.