Privacy Policy

1. Recognition of customer's Expectation of Privacy. We recognize our customers expect us to protect the confidentiality of their accounts, transactions and related member information.

2. Collection and Use of Customer Information. We collect information regarding our customers and our customer's members when we believe it would be useful (and permitted by law) in handling their accounts and transactions with us. Much of this information constitutes nonpublic personal information. This information may be collected from a variety of sources, such as the following:

• Information customers provide directly to us regarding their personal information or their member's personal information, such as a Social Security number, bank account or credit card information; and

• Information about a customer or member's account history with us, such as account balances and payment history.

We use information regarding our customers and our customers' members for a variety of reasons, including facilitation of transactions in servicing a customer's or members account, identification purposes in protecting a customer or member's account and safeguarding against unauthorized access to customer or member's accounts and information, identification of additional products and services that may be beneficial to a customer and identifying and mitigating potential risks or losses to us.

3. Sharing of Customer Information with Third Parties. Our policy is not to share nonpublic personal information about our customers or customer's members with unaffiliated third parties, except where permitted by law, such as:

• The information is provided to help complete a customer/member initiated transaction;

• The customer/member requests the information be disclosed; and

• The disclosure is required by or allowed by law, such as when the disclosure is made in response to a subpoena.

We may also disclose nonpublic personal information to companies which provide support services to us and which agree to maintain standards of confidentiality similar to our standards and to use the information only for the purposes for which it is disclosed.

4. Limitation on Access to and Protection of Information. We authorize our employees to access customer/member information only in situations where a valid business reason for knowing such information exists. Our employees have a responsibility to keep in confidence, what is given to them in confidence. Our operational and data processing systems are in a secure environment that protects customer/member accounts and transaction information from being accessed by unauthorized persons.

5. Providing Privacy Information to Customers and Responding to Inquiries. We make our policy regarding confidentiality of customer information available publicly. Customers who have questions regarding our policy, the privacy of their information, or their member information, should contact us during normal business hours.