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NOTICE OF YOUR FINANCIAL PRIVACY RIGHTS

We, our, and us, when used in this notice, mean Town North Bank , N.A.

This is our privacy notice for our customers. When we use the words “you” and “your” we mean the following types of customers:

• Our consumer customers who have a continuing relationship by purchasing or holding financial products or services such as a(n):

  • Deposit account

  • Loan account

  • Credit card account

  • Safe deposit box

  • Retail installment contract we hold and service

  • Self-directed Individual Retirement Account

We will tell you the sources of the information we collect about you. We will tell you what measures we take to secure that information.

We first define some terms.

Nonpublic personal information means information about you that we collect in connection with providing financial product or service to you. Nonpublic personal information does not include information that is available from public sources, such as telephone directories or government records. Hereafter, we will use the term “information” to mean nonpublic personal information as defined in this section.

An affiliate is a company we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control.

A nonaffiliated third party is a person we do not employ or a company that is not an affiliate of ours. This is also known as nonaffiliated third party, or simply, an “other party.”

THE INFORMATION WE COLLECT

We collect information about you from the following sources:

• Information you give us on applications or other forms
• Information about your transactions with us
• Information about your transactions with other parties
• Information from a consumer reporting agency

THE CONFIDENTIALITY, SECURITY, AND INTEGRITY OF YOUR INFORMATION

We restrict access to information about you to those employees who need to know that information to provide products or services to you. We maintain physical, electronic, and procedural safeguards to protect this information.

YOUR INFORMATION AND OUR AFFILIATES

We may disclose information about you to our affiliates. Here are the kinds of information and the source of that information:

Transaction and experience information from our account records:

• Information about your transactions and experience with us, such as:
  • Name
  • Address
  • Telephone number

Federal law allows us to disclose the information listed above with our affiliates. You do not have a right to opt out of the disclosure of this information.

Types Of Affiliates

We may disclose information about you to the following types of affiliates:

• Financial service providers, such as:
  • Insurance subsidiary
  • Private label credit card issuers

YOUR INFORMATION AND OTHER PARTIES

We will not disclose information about you to anyone except as disclosed in this policy or as permitted by law. Examples of this might include disclosures necessary to service your account or prevent unauthorized transactions.

INFORMATION ABOUT FORMER CUSTOMERS

We do not disclose information about former customers, except as permitted by law.

AUTHORIZED SHARING - JOINT MARKETING

We may disclose the following information to other financial institutions with whom we have joint marketing agreements:

• Information you give us on an application or other forms, such as:
  • Name
  • Address

• Information about your transactions with us, such as:
  • Account balances
  • Account activity
  • Types of accounts
  • Deposit history

   

• Information we receive from a credit reporting agency, such as:
  • Creditworthiness
  • Credit history

We disclose the information listed above with other financial institutions with whom we have joint marketing agreements. You do not have a right to opt out of the disclosure of this information.

Types of Businesses

We may disclose information pursuant to joint marketing agreements to the following types of businesses:

• Financial service providers, such as:
  • Mortgage bankers
  • Securities broker-dealers
  • Insurance companies

Reasons For Disclosing

We may disclose information about you to other financial institutions with whom we have joint marketing agreements to provide you with information about additional products and services.

Limitations on Disclosure

Here are the limitations we impose on the use of information disclosed to other financial institutions with whom we have joint marketing agreements:

• We only allow direct mail solicitations.

YOUR INFORMATION AND OUTSIDE MARKETING SERVICES - FUTURE CHANGES

In the future, we may disclose information about you to outside marketing services, even though we are not doing so now. Here are the kinds of information we may disclose to these services:

• Information you give us on an application or other forms, such as:
  • Name
  • Address

You may not opt out of the disclosure of this information.

Types of Outside Marketers

We may disclose information about you in the future to the following types of outside marketers:

• Service providers that perform marketing services for us, such as:
  • Direct marketers

Reasons For Disclosure

In the future we may disclose information about you to companies that perform marketing services on our behalf to provide you with information about additional products and services.

Limitations on Disclosure

Here are the limitations we will impose on the use of information disclosed to companies that perform marketing services on our behalf:

•  We only allow direct mail solicitations.