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It is the policy of Fidelity Bank to maintain the highest standards of privacy and confidentiality for our customers and their personal information. While information is critical to providing quality service, we realize one of our most important assets is our customers’ trust. The following standards outline the manner in which Fidelity Bank and its employees will collect, use, secure, retain and dispose of individual customer information.

COLLECTION, USE, RETENTION AND DISPOSAL OF INDIVIDUAL CUSTOMER INFORMATION

We will collect, use and retain information about our individual customers only where we reasonably believe that it is useful in administering Fidelity Bank’s business and to provide services. We will collect and use this information only for specific business purposes to protect and administer personal accounts and transactions. We will retain all of the information for the length of time set forth in our internal policies for that product or as set forth by state law. Procedures are in place for the proper disposal of all confidential information. Upon the request of the customer, Fidelity Bank will provide information on why we collect the information we do, how we use it, how long we retain it and how we dispose of it.

MAINTENANCE AND ACCURACY OF INDIVIDUAL CUSTOMER INFORMATION

We will continually strive to maintain complete and accurate information about our individual customers and their accounts. This would include a review of all new accounts added to the computer to ensure accurate input, a review for completeness of any new customer files created, a review, no less than annually, of all records to ensure we are not retaining closed or outdated information longer than necessary, and an employee review of how to properly dispose of confidential information.

LIMITED EMPLOYEE ACCESS TO INDIVIDUAL CUSTOMER INFORMATION

We will educate our employees to understand the vital importance of customer privacy and confidentiality. Employee access to personally identifiable information is only given to those with a reason to know such information. Our policy will be discussed with all new hires during orientation. Annual training will be conducted for all existing employees. All of our employees are responsible for maintaining the confidentiality of personal customer information. Employees who violate these privacy principles will be subject to appropriate disciplinary action.

SECURITY PROCEDURES TO PROTECT CONFIDENTIAL PERSONAL INFORMATION

We will maintain security procedures to help prevent unauthorized access to personally identifiable information. Fidelity Bank has implemented an Information Technology Security Policy and an End User Technology Policy to maintain and manage the Bank’s network and mainframe security. In compliance with the mandatory information security standards contained within the Gramm-Leach-Bliley Act (GLBA), an incident response program is included within the Information Technology Security Policy.

RESTRICTIONS ON THE DISCLOSURE OF ACCOUNT INFORMATION

We will not reveal specific information about any consumer account or other personally identifiable data to third parties for their independent use, except for the exchange of information with reputable credit reporting agencies to maximize the accuracy and security of such information or in the performance of bona fide corporate due diligence unless 1) the information is provided to help complete a customer initiated transaction; 2) the customer requests us to do so; 3) the disclosure is required or allowed by law; or, 4) the customer has been informed about the possibility of such disclosure for marketing or similar purposes through a prior communication.

THIRD PARTY DISCLOSURE RESTRICTIONS

It is sometimes necessary to provide confidential personal information to a third party, such as a vendor or service provider that we hire. Fidelity Bank will insist that the third party adhere to the same strict privacy guidelines that provide for keeping such information confidential as stated in the contents of the Vendor Management Policy and agreements.

DISCLOSURE OF THIS POLICY TO OUR CUSTOMERS

We will provide our Privacy Policy to all new customers at the onset of the relationship (opening of an account, execution of a loan, etc.). This Policy will also be disclosed to our existing customers on an annual basis. It will also be available upon request from our Customer Service Department 952-830-7202.


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