Important Notice Concerning Customer Privacy

When you provide us or we obtain information about you and your financial transactions or accounts that is not publicly available (“nonpublic personal information”), you can be certain that this information will be used only within our strict guidelines. We have prepared this notice to explain what types of nonpublic personal information we collect, how we use it, and under what circumstances we may share it.

We encourage you to read through this notice regarding our position on privacy.

This notice applies only to nonpublic personal information obtained by us in connection with financial products and services primarily for personal, family or household purposes (and not business purposes). This notice takes precedence over any previous privacy notices issued by us.

Information we collect

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on applications and other forms;
• Information about your transactions with us, members of our corporate family (“our affiliates”), or other persons who are not members of our corporate family (“non-affiliates”); and
• Information we receive from a consumer reporting agency (e.g., credit bureaus and others);
• Information we receive from you by e-mail.

Information we disclose and to whom

We may share with our affiliates nonpublic personal information regarding our transactions with our customers (such as name and address).

We may disclose the nonpublic personal information we collect about you to nonaffiliates, as permitted by law. For example, certain federal or state laws may require us to disclose information about you if you are involved in litigation with a third party. In such circumstances only the specific information required by law, subpoena or a court order will be disclosed.

We may from time to time disclose nonpublic personal information received from you on applications and other forms, such as your name and address, to nonaffiliated companies that perform marketing services on our behalf with regard to our own products or services.

We may disclose nonpublic personal information about you to other financial institutions with which we have joint marketing arrangements or to nonaffiliated companies with which we have outside service provider arrangements, as follows:

• Joint marketing providers: From time to time, we may select joint marketing providers to offer our customers specialized financial services, such as mortgage life insurance. Although these providers would not be our affiliates, they would work closely with us to help meet certain of your financial needs. If appropriate, we may disclose to these providers information received from you on applications or other forms, such as your name and address.
• Outside service providers: From time to time, we may enter into arrangements with non-affiliated companies or firms whose expertise is essential for our own services to function properly or to complete transactions. For example, we may work with specialized firms that generate disclosures and forms that we give to our customers. As permitted by law, we disclose to these service providers the customer information that is necessary to perform these functions.

These marketing companies and joint marketing and outside service providers are required by us to safeguard the confidentiality of your nonpublic personal information and use it only for authorized purposes.

Former customers

We may disclose nonpublic personal information about our former customers, as described in the preceding section of this notice.

Online services and Privacy

We are in the process of developing our website. When the website development is completed, you can visit our website and learn about our products and services. We will maintain a transactional website for our products and services. We will retain any information you provide to us on our website, and we will store information about you (i.e., “cookies”) when you visit our website.

We may obtain e-mail addresses from our customers who want to communicate with us by email. We do not disclose e-mail addresses to anyone, except as permitted or required by law. Typically, we do not initiate the first e-mail communication with our customers about their transactions. We may from time to time respond by e-mail to e-mail inquiries from our customers about their transactions.

From time to time, we may send by e-mail to our customers information about our products or services. If you do not want to receive this information from us by e-mail, you may request at any time that we not send any more information by e-mail to you.

We respect your privacy

We restrict access to your nonpublic personal information to our employees, agents or other similar persons who need to know that information to provide products and services to you.

We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Your trust is important to us. We are committed to protecting your privacy, whether you do business with us in person or online or by telephone or mail.

If you have questions concerning our privacy policy please let us know.

We welcome your questions & comments.