Children’s Online Privacy Policy

LAST UPDATED: May 31, 2025

Your child’s privacy is important to us. This Children’s Online Privacy Policy explains how we collect, use, and disclose personal information collected online from children under the age of 13 in compliance with the Children’s Online Privacy Protection Act (“COPPA”). All information below and references to “Your Child” pertain exclusively to children under the age of 13. For more information on Orion’s privacy and security practices for Orion online services, please see our Privacy Policy.

Personal Information We Collect About Your Child

Before your child uses Orion Youth Banking, you must enroll them into the program and consent to our collection, use, and disclosure of their personal information in connection with their participation in Orion Youth Banking. We won't require your child to disclose more personal information than is necessary to interact with the program. Orion Financial uses certain third-party vendors to facilitate or otherwise enable Orion Youth Banking. These vendors are Q2 Software, Inc.; Fidelity Information Services, LLC; Doxim IDS, LLC; and Alogent Holdings, Inc. For information about these vendors and the services they provide, please contact us at the contact information below.

What Personal Information We Collect

During enrollment you'll provide your child’s name, date of birth, address, and social security number. This information is required under federal and state laws. We also require an email address for your child but you can opt to put your email address if your child doesn't have one. You're required to create a username/password for the child’s online account access. When your child uses Orion Youth Banking, they'll have the ability to make changes to their personal information such as their:

• account nickname;
• telephone number(s);
• physical address (this doesn't change the address on file that account documentation is mailed to);
• email address; and
• username and password.

By enrolling your child in Orion Youth Banking, you consent to our collection of the personal information above to the extent your child chooses to update his or her profile, which may occur without notice to you. As described below, you have the right at any time to review the personal information we collect from your child online, refuse to allow further use or collection, or request deletion of that information.

Usage and Other Information

In addition to the personal information described above, we may collect certain information about your child’s use of our online services. For example, we may capture the IP address of the device they use to connect to Digital Banking, the type of operating system and browser they use, and information about the site they came from, the parts of our Digital Banking services they access, and the site they go to next. We or our partners may also use cookies, web beacons, or other technologies to collect and store other information about their visit to, or use of, our Digital Banking services. In addition, we may later associate the usage and other information we collect online with personal information about them.

Digital Banking

When your child interacts with us through Digital Banking (as defined in our Digital Banking Agreement), we may also collect information such as unique device identifiers for their mobile device, screen resolution and other device settings, information about their location, and analytical information about how they use their mobile device.

Use of Information

We use the information discussed above in a number of ways, such as:

• Processing transactions;
• Verifying your child’s identity (such as when they access their account information);
• Preventing fraud and enhancing the security of their account or Digital Banking;
• Responding to their requests and communicating with them (which will include sending any text or email account alerts that are activated for the account);
• Managing their preferences;
• Performing analytics concerning their use of our Digital Banking services;
• Operating, evaluating, and improving our business (including developing new products and services; improving existing products and services; performing data analytics; and performing accounting, auditing and other internal functions);
• Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies; and
• For any other purposes that we may specifically disclose to you during enrollment or in connection with your or your child’s use of Orion Youth Banking.

We may also use data that we collect on an aggregate or anonymous basis (such that it doesn't identify you or your child) for various business purposes, where permissible under applicable laws and regulations.

Disclosure of Information

We may share the information we collect from and about your child with our affiliates and others. For example, we may share their information with:

• Our service providers;
• Successors or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger; and
• Others to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties.

Parent or Legal Guardian Rights

As a parent or legal guardian, you have the right to:

• review the personal information collected online from your child;
• refuse to allow further use or online collection of personal information from your child; and
• delete the personal information collected online from your child (unless we're required by law to retain).

Orion Youth Banking may constitute an online interactive experience. If you don’t want us to continue to collect or use your child’s personal information, or if you ask us to delete it, we may be required to remove their online profile and close the Orion Youth Banking account.

To exercise any of these rights, please contact us by any method listed below.

Contact Details

If you have any comments, questions, or concerns about any of the information in this Policy please contact us by phone at 888-506-9001, by mail at 400 Monroe Avenue, Memphis TN 38103, or by email at privacy@orionfcu.com.