First Volunteer Bank compiles and maintains confidential information on customers as an integral component of delivering banking products and services. As financial service professionals entrusted with sensitive financial information, we respect the privacy of customers and are committed to treating customer information responsibly. It is the policy of First Volunteer Bank to protect the privacy of customer information according to not only state and federal laws, but even more importantly, by our own strict standards.

Recognition of a Customer’s Expectation of Privacy

First Volunteer Bank recognizes that one of our fundamental responsibilities is to safeguard sensitive financial information. In addition to the safeguard controls established by the Information Security Program, the bank will maintain standards and procedures designed to prevent the inappropriate sharing or misuse of this information.

Collection, Retention, and Use of Information

Information about consumers is accumulated from a variety of sources. Some information is provided to First Volunteer Bank directly by customers themselves. Other data is developed by First Volunteer Bank as a function of providing a product or service to a customer. Still other information is obtained from outside sources. We will limit the use and collection of customer information to what is necessary to administer our business, provide superior service, and offer opportunities that we think will be of interest to customers. This means that we will use information to help us identify and mitigate potential risks or loss to First Volunteer Bank. We will use information to help identify additional products or services, which we believe customers, might want to know about. We will use this information only in accordance with the stated principles in this Policy.

Maintenance of Accurate Information

First Volunteer Bank continually strives to maintain accurate, current and complete financial information. We pledge to respond to requests to correct inaccurate information in a timely manner.

Limiting Employee Access to Information

At First Volunteer Bank, we have procedures that limit employee access to customer information to those employees with a business reason to know such information. Employees are informed of their responsibility to protect confidential information and are bound by our Code of Ethics, which addresses the importance of confidentiality.

Security Procedures to Protect Information

First Volunteer Bank will continue to maintain and grant access to customer information only in accordance with our internal security standards.

Restrictions on the Disclosure of Account Information

It is First Volunteer Bank’s policy not to reveal specific information about customer accounts or other personally identifiable data except for the exchange of information with reputable information reporting agencies to maximize the accuracy and security of such information or in the performance of bona fide corporate due diligence or business matters, unless (1) the information is provided to help complete a customer-initiated transaction; (2) the customer requests or permits it; (3) the disclosure is required by or allowed by law (e.g., subpoena, investigation of fraudulent activity, request by regulator, etc.); or (4) the customer has been informed about the possibility of disclosure for marketing or similar purposes through a prior communication and given the opportunity to decline (opt out).

Sometimes it is necessary to provide specific customer information to a third party, such as a vendor or service company that we hire to provide operational support or to provide support of services for one or more of our products. As specified by First Volunteer Bank’s Third Party Management Program, these third parties are subjected to reviews to ensure the information provided is appropriately protected and used only for the purposes intended.

Privacy Commitment

At First Volunteer Bank, our customers are our top priority. We recognize and respect their privacy expectations and we are committed to complying with the laws and regulations that protect confidentiality of customer information.



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