Financial Privacy & Security Policy

Safeguarding the Security of our Customers' Information.

We recognize the importance of protecting the privacy of our customers by keeping the information we obtain secure and accurate. We respect their expectations and adopt these policies to maintain our customers' trust. All directors, officers, employees and affiliates of our institution are obligated to keep the information entrusted to them confidential. We will provide our customers initially and annually with our policy on using responsibly and protecting their personal financial information.

The objective of this policy is to explain what kind of information we collect, how the information we collect may be used, with whom and under what circumstances it will be shared and how the information remains confidential and accurate.

What Kind of Information We Collect

We may collect "nonpublic personal information" about our customers from the following sources:

• Information we receive from them on applications or other loan and account forms;
• Information about transactions with us, our affiliates or others; and
• Information we receive from third parties such as credit bureaus.

Click here to view the Privacy brochure.

How We Use the Information We Collect.

The information we collect is used to perform basic banking functions and to provide superior customer service. By using information our customers voluntarily provide to us, we are able to offer specific products and services we believe will be the most beneficial to our customers. Additionally, federal and state loan related regulations require us to collect and retain certain information in accordance with consumer protection laws. This information will be used to ensure our compliance with anti-discriminatory laws; however, disclosure of this information is strictly voluntary. Further, we maintain information about our customers' transactions, including repayment history, average balances and other pertinent account information. This information will be used to ascertain our current banking relationship with our customers, as well as possible needs for products and services. We do not share any medical information we collect unless the customer authorizes it.

What Information We May Disclose

We do not disclose any nonpublic personal information about our customers to any third parties, except as permitted by law.

We are permitted under law to disclose nonpublic personal information about our customers to "nonaffiliated third parties" (i.e., third parties that are not members of our corporate family) in certain circumstances. For example, we may disclose nonpublic personal information about our customers to such third parties to assist us in servicing loans or accounts with us; to government entities in response to subpoenas; and to credit bureaus. We do not disclose any nonpublic personal information about our customers to any other third parties, except as permitted by law.

In addition, we may disclose the following information to companies that perform marketing services on our behalf or to other financial institutions with which we have joint marketing arrangements:

• Information we receive from our customers on applications or other forms, such as name, address, social security number, assets and income;
• Information about transactions with us, our affiliates or others, such as account balance, payment history, parties to transactions and credit card usage; and
• Information we receive from credit bureaus, such as creditworthiness and payment history.

We also are permitted under law to share information about our experiences or transactions with our customers with companies related to us by common control or ownership ("affiliates"). We also may share additional information about our customers with our affiliates. However, if a customer directs us not to share this information, we will not.

Who We Will Share The Information With

Our officers and employees are permitted to access the information they need to perform the duties and procedures of their jobs. All directors, officers and employees are instructed on the confidentiality policies of our institution and emphasis is placed on the importance of our customers' privacy. Further, accuracy is a vital key to our integrity within the financial community. Our customers are instructed on their account statements to contact us with any errors and we will investigate any discrepancies in an efficient manner. A prompt response, in accordance with applicable laws, will be given to each customer. All errors will be corrected in a timely manner.

We may share information for joint marketing about selected customers to our business partners whom we feel may provide beneficial products or services to our customers. These non-affiliates must agree to not share the information obtained from us with any other party. Further, we will not sell customer information to any outside vendor.

How We Maintain Safe and Accurate Information

All customers are instructed on their account statements to contact us regarding any errors or discrepancies. Further, each new customer is instructed to notify us of any possible unauthorized access to his or her account information. All complaints will be investigated and detected errors will be corrected immediately. Finally, all customers are allowed to review and correct any erroneous or outdated information by contacting us at any location.

Summary

With the continual advancement of computer technology, protecting the privacy of information has become an increasing concern with our customers. We recognize the growing risk and are committed to maintain our customers' trust and confidence by insuring all directors, officers and employees meet the privacy policies.