Privacy Policy

1. Acknowledgment of Privacy as a Fundamental Expectation

   We acknowledge that the privacy of your personal and financial affairs is an inherent expectation. We understand our responsibility to safeguard sensitive information about these affairs which you have entrusted to us. We maintain policies and procedures designed to prevent misuse of this information.

2. Our Collection, Retention, and Use of Information about You

   We collect, retain, and use information about you only when we have a reasonable belief that such information will help us administer our business or provide products, services, and other opportunities to you. Information about you is collected and retained only for specific business purposes. We use information to protect and administer your records, accounts, and funds; to comply with certain state and federal laws and regulations; to help us develop or improve our products and services; and to understand your financial needs and provide you with quality products and service.

3. Our Maintenance of Accurate Information

   We have procedures to assist us in assuring that your financial information is current, complete, and accurate in accordance with established standards. We also have procedures in place to help us respond to your requests to correct inaccurate information in a prompt fashion. State and federal law mandate many of these procedures; however, we have implemented additional procedures to maintain current, complete and accurate financial information, including procedures to update information and to remove stale information.

4. Limiting Employee Access to Information

   We have security policies and procedures that limit employee access to personally identifiable information to those employees with a business purpose for accessing such information about you. We train and educate our employees about the importance of member privacy and confidentiality through our standard operating procedures.

5. Security Procedures to Protect Information

   We maintain security procedures to avoid unauthorized access to confidential information about you.

6. Restrictions on Disclosing Information to Parties Outside of our Institution

   We refuse to reveal specific information about your accounts or other personally identifiable data to parties outside our institution unless: (1) you request or

   authorize it; (2) the information is provided to assist a transaction initiated by you; or, (3) the information is provided to a reputable credit bureau or similar information reporting agency.

7. Maintaining Your Privacy in Business Relationship with Outside Third Parties

   Sometimes it is necessary in the normal course of business to provide personal, identifiable information about you to a third party, such as to provide support or service for one or more of our products. When this is necessary, these service providers and vendors agree to the same stringent privacy standards to which we and our employees are committed.