1. Initial log-on/authentication – To become an Authorized User of the cooperative.com website, the prospective user will be required to provide for authentication purposes some personally identifiable information in order that it can be compared to existing user profile personally identifiable information already existing in the Association Management System ("AMS") database maintained by NRECA. Once the information is provided and authentication is completed, a copy of the AMS database information will be automatically transferred to NRECA for use in building a cooperative.com Authorized User database. This information will also be used to facilitate the cooperative.com people-finder and similar future internal capabilities. Information, such as name, business address/phone/fax, e-mail/position/title, are normally utilized for these purposes. Other personal information, such as an Authorized User's Social Security number, will also be included in the authorized user database, but this sensitive personal information will only be used for the purposes of identification and authentication. Sensitive personal information will not be included in the people-finder service or any other similar service generally accessible to Authorized Users or any third party. Prospective users may effectively opt-out of NRECA's use of any of this information for any of these purposes by simply declining to provide the requested information. Failure to provide this information, however, will preclude access for such user to the password-protected portion of the cooperative.com website. Once authentication is completed, the newly Authorized User may review and correct any ​personally identifiable information contained in the cooperative.com user database or any other NRECA or sponsor database.
   

2. Web server log information – This is basic information that does not identify any specific individual that is collected on all User visits such as the domain and the address of the website from which cooperative.com was accessed, IP address, type of browser or operating system, date, time, duration of access, pages visited and links visited on the website. This information is automatically (involuntarily) collected and may be used to help NRECA improve and maintain the availability and usefulness of the website for Users. This information is used in the aggregate for this purpose and no attempt is made to identify any specific individual. Users cannot opt-out (except by failing to authenticate as discussed above at 1) of collection of this information and it is not reviewable or correctable by the User because we do not maintain it in a way that is personally identifiable.
   

3. Cookies – Cookies are another means by which NRECA collects information on all User visits. Cookies are bits of information collected by the web server and transferred back to the User's computer, phone, tablet, or other device to enable NRECA systems to recognize such device. NRECA uses cookies that collect aggregated information that do not identify any specific individual. This information is automatically collected, and no attempt is made to identify any specific individual. NRECA also uses cookies that collect non-aggregated information that identifies and assigns Authorized Users a unique identifier generated by the NRECA email platform. Authorized Users who have consented receive marketing emails containing links with this type of cookie. This information is voluntarily provided, and Authorized Users may opt-out of this information collection as describe below. Both types of cookies collect information that is used to help tailor or personalize the User's next ​visit to cooperative.com and to otherwise manage and improve the website. Users may opt-out of the collection of aggregated information by failing to authenticate as discussed above at 1). Users may also be able to set their browsers to alert the User of the creation of a cookie and/or a means to deny acceptance of a cookie. This information is not reviewable or correctable by the User because we do not maintain it in a way that is personally identifiable. The Help feature on most browsers will tell users how to prevent your browser from accepting new cookies, how to have the browser notify users when such user receives a new cookie, or how to disable cookies altogether. Authorized Users may opt-out of non-aggregated information collection via marketing emails by not following the link within the email, or if available, by selecting the appropriate option within the email.​

4. Requests for products/services/information – When Users request products, services, or information from, or respond to surveys conducted by, NRECA through this website, personally identifiable information such as name, email address and credit card number may be collected in order to complete the transaction. Failure to provide the requested information, however, may preclude delivery of the product, service or information requested. This information is voluntary and each User can opt-out of providing this information by simply not providing it as requested (or by failing to authenticate as discussed above at 1). The User can also opt-out of any future use of this information for any other purpose such as notification of new services, products or information by indicating their desire within the communication requesting such service, product or information or, if available, by clicking the appropriate icon. Any personally identifiable information provided in this way can be reviewed and corrected by the User.
   

HOW NRECA MAY USE INFORMATION​

1. To present this website and its contents to Users and Authorized Users.
   

2. To respond and provide Users and Authorized Users with information, products, or services requested from NRECA and its suppliers.

3. To offer products, services or information that Users and Authorized Users may find helpful.

4. To provide Authorized Users with important notices about their account or benefit information.

5. To notify Users and Authorized Users about changes to our website or any products or services NRECA offers.

6. To allow Users and Authorized Users to participate in interactive features, including advertisements, made available through cooperative.com.

7. To implement new services similar to the People Finder service and making Authorized Users aware of website features, improvements, modifications, etc.

8. In any other way NRECA may describe when information is provided.
   

9. For any other lawful purpose with consent.

DISCLOSURE OF INFORMATION

Any information collected and retained by NRECA through this website will not be released to third parties except as indicated below:

1. Any updates to the information in the cooperative.com user profile database will be disclosed to the appropriate sponsor of the Authorized User (e.g. National Rural Electric Cooperative Association (NRECA), National Rural Utilities Cooperative Finance Corporation (CFC), Federated Rural Electric Insurance Exchange (Federated), or Touchstone Energy Cooperative, Inc., or any combination thereof) and the AMS database maintained at NRECA to ensure that the information that each appropriate sponsor has about the Authorized User is accurate.

2. Any information needed by a vendor to perform services for NRECA or other appropriate sponsor will be disclosed to the vendor. Such vendor will be required by contract to observe the same privacy protections that apply to this website, and they will not be allowed to sell User information.

3. Any necessary information will be disclosed to any appropriate internal or external authorities in order to 1) identify and pursue remedies against Users who attempt to damage, misuse, or otherwise interfere with the operations of this website, or 2) to otherwise protect NRECA's legal interests.

4. NRECA may aggregate information collected on the website, such as views or clicks, and share with third parties for NRECA's business purposes.

5. Any necessary information required to respond to appropriate requesting authorities, including but not limited to, properly issued search warrants, court orders, or subpoenas. NRECA will make every reasonable effort to limit such disclosures. NRECA may also disclose User personal information to enforce the Terms of Use to this website.

6. NRECA may disclose to each voting member ("Member(s)"), upon request of such Member's CEO: (1) the names and email addresses of all Member's employees or consultants that have subscribed to any NRECA listServ or forum using the Member's domain name; and (2) the NRECA listServs or forums to which such employees or consultants are subscribed.
   

INFORMATION SECURITY

NRECA, as owner of this communication service, has implemented commercially reasonable technical, administrative, and physical security measures in order to protect personally identifiable information against loss, unauthorized access, destruction, misuse, modification, and improper disclosure of all information collected and maintained by NRECA on the password-protected portion of this website.

As a critical part of these security measures, NRECA monitors any and all communications and data traversing the site. That monitoring may include actual content of those communications and data as necessary.

While no information is absolutely safe in an electronic environment, by implementing commercially reasonable security, NRECA has taken appropriate steps to secure information collected, retained and used.

NRECA encourages Authorized Users to take steps to reduce the risk of fraud and to help protect the confidentiality and security of their cooperative.com account and personal information, including but not limited to the following:​

• Create strong usernames and passwords with 15 or more characters using both upper- and lower-​case letters, numbers and special characters
  

• Do not use dictionary words and avoid sequences such as “abc”, “567”, etc.

• Do not share passwords with others nor write your password down
  

• Do not use the same password on more than one website nor reuse and repeat passwords

• Change your passwords if you believe your information has been compromised​

• Consider using a secure password manager to help create and track passwords
  

• Password protect and lock your device(s)

• Maintain up-to-date antispyware, antivirus and firewall software to protect your device(s)

• Look out for suspicious or “phishing” emails and do not click on unrecognized links or attachments

• Log out of website sessions so that the user session is closed and close your browser

• Be wary of using public computers and free Wi-Fi networks as these may pose security risks to your personal information

• Routinely monitor your online account

• ​Update your contact information when it changes so you can be contacted if there’s a problem
  

REVIEW AND CORRECTION OF ​COLLECTED INFORMATION

Authorized Users of cooperative.com may, upon a verified request, review and correct as needed or desired any sensitive, non-personally identifiable information or personally identifiable information collected or retained by NRECA by contacting NRECA's Privacy Officer at: (Mail) NRECA, 4301 Wilson Blvd, OGC9-118, Arlington VA 22203-1860; or (email) privacyofficer@nreca.coop.

USER CALIFORNIA PRIVACY RIGHTS

California Civil Code Section §1798.83 permits Authorized Users of cooperative.com that are California residents to request certain information regarding NRECA's disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacyofficer@nreca.coop or write us at: (Mail) NRECA, 4301 Wilson Blvd, OGC9-118, Arlington VA 22203-1860.

DO NOT TRACK

Some web browsers incorporate a "do not track" feature that, when enabled, signals to websites and online services that you do not wish to be tracked. Because there is not yet an accepted standard for how to respond to such a do-not-track signal, we do not recognize or respond to these signals.

CHANGES TO WEBSITE PRIVACY POLICY

From time to time, NRECA may revise this policy to reflect changes in the law, changes in our products or services, changes in our practices regarding the collection and use of personal information, or to reflect new features or technologies of cooperative.com. Authorized Users of cooperative.com will be notified of all changes to the substance of this policy through postings on cooperative.com alerting them to affirmatively review the changed policy posted on the cooperative.com website. NRECA encourages all Users to review this policy periodically so that they are up to date on NRECA's most current policies and practices. The last date this policy was revised is the effective date set forth above.

NRECA EMPLOYEE BENEFITS WEBSITE

A separate privacy policy governs information collected through the NRECA Employee Benefits website, a website accessible once logged onto cooperative.com as an Authorized User. Please review the NRECA Employee Benefits website's privacy policy to better understand how the information collected on that website will be maintained, used and disclosed.

QUESTIONS

Any questions about this policy may be directed to NRECA's Privacy Officer, in writing, to: (email) privacyofficer@nreca.coop or (Mail) NRECA, 4301 Wilson Blvd, OGC9-118, Arlington VA 22203-1860.