Privacy Policy

At the Bank of Sullivan, every customer relationship is based on the basic standard of trust and we will treat our relationship with great care and consideration. We realize that our responsibilities extend beyond meeting the financial needs of our customers. Concerns for customer privacy and confidentiality are cornerstones of banking. We must make every effort to protect the sensitive and confidential information of our customers and ensure their privacy is never compromised.

Customer Privacy is Important to us

The Bank of Sullivan recognizes that customers have a right to expect their personal financial information to remain private and secure. Because customer privacy is important to us, we have always maintained standards that ensure customer information is private and secure at all times. In order to make certain these standards are maintained, we have appointed a member of the bank's management team as Privacy Officer. The bank's Compliance Officer will serve as Privacy Officer and assume responsibility for implementation of the bank's Privacy Policy.

Use, Collection, and Retention of Customer Information

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

• Information we receive from customers on applications or other forms
• Information about customer transactions with us or others
• Information we receive from a consumer reporting agency

The collection and use of nonpublic personal information about our customers is limited to business purposes.

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

However, we may disclose information we receive from or concerning you, as described above, such as your name, address and type of account to companies that perform services on our behalf, or to other financial institutions with whom we have joint marketing agreements. Any company or financial institution that receives information from us is not allowed to share, sell or use the information that they are provided in any manner other than what is necessary to perform the function or service.

If a customer decides to close their account or become an inactive customer, we will adhere to the privacy practices as described in this notice. Customer information will only be used in accordance with the principles set out in this Policy.

Maintenance of Complete and Accurate Information

The Bank of Sullivan makes every effort to maintain complete and accurate information regarding customers and their accounts. If it is ever determined that our records contain inaccurate or incomplete information about a customer, corrective action will be taken immediately.

Employee Access to Information

At the Bank of Sullivan, employees are required to limit their access to customer information to a need-to-know basis. Employees are educated on the importance of maintaining the confidentiality of customer information and on this Privacy Policy. Because customer Privacy is so important to us, all bank employees are responsible for maintaining the confidentiality of customer information and any employees who violate this policy will be subject to disciplinary actions that include dismissal.

Security Procedures to Protect Information

We are committed to the security of your financial and personal information.

We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard the nonpublic personal information of our customers.

Restrictions on Disclosure of Information

It is the policy of the Bank of Sullivan to limit sharing any nonpublic personal information about customers to the following:

• Customer requests or authorizations - verbal requests will require customer to provide account number and some other identifying information (such as social security number, address, etc.).
• Information provided to help complete a transaction initiated by the customer with authorization from the customer.
• Verification of funds will be strictly limited to responses of that item will or will not clear. The name of the person calling, the account number they are inquiring about, and the dollar amount they are verifying should always be obtained.
• Loan payoff information will only be provided with written authorization of the loan customer.
• Requests for information regarding a customer's credit with us will only be completed with written authorization of the customer.
• Companies that perform account processing and internet banking support services on our behalf.
• Information provided to a reputable credit bureau or similar information reporting agency.
• The release of information is required or allowed by law (i.e. subpoena, investigation of fraudulent activity, etc.).

Customer Privacy in Business Relationships with Third Parties

Third parties who conduct business with the Bank of Sullivan are required to maintain similar standards of conduct regarding the privacy of personally identifiable information provided to them.

Providing Privacy Information to Customers

At the Bank of Sullivan, we want our customers to understand our commitment to the privacy of customer information. This Privacy Policy has been developed as a result of this commitment and is to be adhered to by all Bank of Sullivan employees. The following privacy statement summarizing this privacy policy has been developed to be given to all Bank of Sullivan customers.

This disclosure will be provided to all existing customers prior to the July 1, 2001 mandatory compliance date and will be posted on the bank's web site. At that same time, bank employees will begin giving this disclosure to all customers when they establish a customer relationship with the bank. This disclosure will be provided annually thereafter to all customers who have a continuing customer relationship with the bank. Any time the bank makes any changes to it's privacy policy or procedures, these changes must be disclosed to all customers within a reasonable amount of time before the changes take place.

At the Bank of Sullivan, we want our customers to understand our commitment to the privacy of customer information. If you have any questions about our Privacy Policy or the privacy of your personal information, please contact us at (573)-468-3191 or 800-645-3191.