California Consumer Privacy Statement

Effective: January 1, 2020

This California Consumer Privacy Statement supplements the Privacy Policy.  It applies solely to California consumers and addresses personal information we collect online and offline. This Statement does not apply to CoBank personnel or job applicants, or the personnel of our business customers.

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, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, and similar technology; customer number; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, Social Security number, driver’s license number, passport number, and other similar identifiers
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, state identification card number, bank account number, credit card number, debit card number, and other financial information
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as age, sex, gender, and gender identity
  • 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 Policy.  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
  • Commercial Information
  • Online Activity
  • Employment Information
  • Inferences
Auditing related to a current interaction with you and concurrent transactions
  • Identifiers
  • Online Activity
Short-term, transient use
  • Identifiers
  • Online Activity
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Identifiers
  • Online Activity
Debugging to identify and repair errors that impair existing intended functionality
  • Identifiers
  • Online Activity
  • Inferences
Undertaking internal research for technological development and demonstration
  • Identifiers
  • 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
  • Online Activity
  • 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, and (c) 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, such as when you send us your contact information
  • Identifiers
  • Inferences
From your devices, such as on our website
  • Identifiers
  • Online Activity
  • Inferences
Our affiliates and subsidiaries
  • None
Vendors who provide services on our behalf 
  • Identifiers
  • Online Activity
  • Inferences
Social networks
  • Identifiers
  • Online Activity
  • Employment Information
  • Inferences

b. Sharing of Personal Information

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

Purposes Categories of Personal Information
Our affiliates and subsidiaries
  • 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
  • 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
  • Online Activity
  • Sensory Information
  • Employment Information
  • Inferences
Data analytics providers
  • Identifiers
  • 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
  • Online Activity
  • Inferences

c. Sale of Personal Information

We do not (and will not) sell personal information unless we post a notice of the right to opt out of such sale and comply with other relevant legal requirements.

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
  • Commercial Information
  • Online Activity
  • Employment Information
  • Inferences

3. California Consumer Privacy Rights

You may have certain choices regarding our use and disclosure of your personal information, as described below.

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

Opt-Out of Sale: California law provides consumers with the right to opt-out of the sale of personal information. We do not sell consumers’ personal information.

How to Submit a Request: To submit an access or deletion request, email us at connect@cobank.com or call us at 800-542-8072.

This Statement, and the access and deletion rights described herein, does not apply to CoBank personnel or job applicants, or the personnel of our business customers.

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 do not have an email address or other direct contact information on file with us, then there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA. The reason for this is that CoBank historically has not linked IP addresses, device identifiers or other information collected through automated means to named actual persons. Accordingly, if you do not have an email address or other direct contact information on file with us, and you request access to or deletion of your personal information, we will not be able to process your request at this time.

If you have an email address or other direct contact information on file with us, and you request access to or deletion of your personal information, we may require you to provide us with certain information to allow us to verify your identity. 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 (1) we may require you to provide the authorized agent written permission to do so, and (2) 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.